The FCA has published the results of its KPMG-led industry evaluation of proposals for the UK’s Open Banking Future Entity. Open Banking Limited emerged as the preferred candidate, scoring 63.88 out of 76 against the Smart Data Group’s 46, across six categories including governance, technical capability, and funding feasibility.
It is a significant moment. The Future Entity will shape how the UK’s open banking market is governed as it moves from implementation into maturity — setting standards, convening industry, and laying the foundations for the Long-Term Regulatory Framework (LTRF) expected at the end of 2026.
The debate about who should lead that process matters. But there is a different question that has received far less attention — and it is the one the industry needs to answer before the LTRF lands.
What a standard-setting body can and cannot do
Both OBL and SDG put forward serious proposals. The evaluation covered governance, independence, technical capability, funding feasibility, risk management, and operational readiness. These are the right criteria for assessing which organisation is best placed to convene industry for the design phase.
But governance of the standard-setting process is not the same as accountability infrastructure for the market it governs. And it is the latter that is almost entirely absent from the current debate.
A Future Entity can define what participants must demonstrate to join the market. It can update standards as technology and regulation evolve. It can resolve disputes about the rules and provide the industry forum that open banking’s next phase requires.
What it cannot do is verify that a participant’s risk posture is sound in real time. It cannot detect when an aggregator’s security controls have degraded since their last assessment. It cannot ensure that when a data breach occurs across a chain involving a bank, an aggregator, and a third-party provider, liability is assigned to the right party — backed by something more durable than a contractual clause.
These are not edge cases. They are the normal operating conditions of a mature open finance market. And they require infrastructure that works continuously, not periodically.
The picket fence problem
UK open banking regulation works vertically. Each regulator governs within its jurisdiction. The FCA oversees UK participants. Standards apply within defined boundaries.
But open finance moves horizontally — through intermediaries, across third-party providers, between jurisdictions. Supervision is periodic and point-in-time. The gaps between oversight moments are where risk accumulates.
A standard-setting body, however well-designed, cannot close that gap on its own. It sets the rules at the boundary. It does not monitor what happens in the space between assessments, or across the full chain of participants that a single customer data flow might traverse.
The industry has spent a decade building the capability for data to move. The infrastructure for accountability when that movement goes wrong has not kept pace.
What the LTRF window means
The Long-Term Regulatory Framework is the moment at which the rules of open banking become durable. Participation expectations will be set. Accountability obligations will be defined. The market will move from a supervised implementation phase to a functioning market.
That transition demands more than a well-designed governance structure. It demands a network layer that sits beneath governance — one that accredits participants to a consistent standard before they join, monitors their risk continuously while they operate, and ensures that financial accountability is in place when something goes wrong. That clock is running.
The Future Entity will produce that governance structure. The question is whether the accountability infrastructure is built alongside it, before the LTRF lands, or discovered to be missing after the first significant incident in a mature open finance market.
That is not a question for the design phase alone. It is a question for every financial institution, intermediary, and third-party provider operating in the market today.
Invela is building the answer
Invela is building open finance risk management across three integrated layers: standardised Accreditation; dynamic risk intelligence via the Invela Risk Indicator; and insurance-backed Warranty — which will provide the financial backstop, ensuring liability lands in the right place. Invela operates across the US, UK, and Canada.
The Future Entity debate is necessary. The accountability layer is what makes it sufficient.
Open finance, covered.
