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This 12-week assessment is designed to identify which organisation is best positioned to lead the creation of a Future Entity (FE) that can be formally designated once statutory powers are in place. While feedback from previous consultations indicated that the majority of the industry supported a specific direction, views remained divided and lacked unanimity. Consequently, Andrew Self, the FCA’s head of Open Banking and Open Finance, has emphasised the importance of a swift, unbiased exercise to maintain momentum and clarify the FE’s delivery requirements.

Two primary contenders have emerged to lead this transition. The Smart Data Group has proposed that the Future Entity be operated by Smart Data Services, a new not-for-profit company intended to provide shared core services across both regulatory and commercial schemes.

Open Banking Limited (OBL) has also put itself forward, with CEO Henk Van Hulle noting that the organisation has already received endorsement from seven trade associations to facilitate a neutral and cost-effective design for the new entity.

Throughout this process, the FCA will maintain oversight for governance and contract management to ensure value for money, but it will not participate in or influence the substantive evaluation of the competing proposals.

Firms are encouraged to share their analysis with KPMG either directly or through trade associations to ensure the final recommendation reflects broad industry sentiment. Although the resulting recommendation will not be legally binding, it is intended to provide a robust foundation for decision-making ahead of the Open Banking Statutory Instrument, which HM Treasury is expected to lay by the end of 2026.

KPMG is scheduled to share its final report with trade associations and the FCA in early April 2026, after which the regulator will publish the findings to ensure transparency across the ecosystem.