MEMA Scope · Assessment
Do open banking providers need FCA authorisation?
A business gets access to customers’ payment accounts with their consent to show them their data, or initiates payments from their accounts. Review the initial view below and answer a few questions to refine it.
- Personalised to your business
- FCA rule references
- Follow-up questions available
Potential regulated activity identified
Open banking services may require registration or authorisation
Account information services alone are registered. Payment initiation needs authorisation as a payment institution.
Route to consider: Registration rather than full authorisation
Why this was flagged
- 1Accessing account data for a customer with their consent is an account information service.
- 2Initiating a payment from a customer’s account at their request is a payment initiation service.
Questions still to resolve
Answer to refine the view. The result updates as you go.
- ?
Will you only read account information, and never initiate payments?
- ?
Will you ever hold customer funds, even briefly?
- ?
Will you rely on a regulated open banking provider and only present its service in your app?
Regulatory basis to examine
Your next steps
- 1Decide whether you do account information only or payment initiation as well
- 2Arrange professional indemnity insurance or a comparable guarantee
- 3Document consent, security and customer authentication arrangements
- 4Apply for registration or authorisation as appropriate
Where applications for this model most often fall short
- Professional indemnity insurance evidence
- Consent management and data security design
- Clarity on whether funds ever touch your accounts
This is an initial indication from published FCA material, not an FCA determination or legal advice.
If authorisation is required, check the firm’s governance, policies, resources and application preparedness.
MEMA Scope gives an initial view from published FCA material. It is not legal advice or an FCA determination. Automatic matching and typed questions use AI only to choose a profile and to answer from vetted guidance; the assessment itself is never written by AI.
About this business model
A business gets access to customers’ payment accounts with their consent to show them their data, or initiates payments from their accounts.
Account information services alone are registered. Payment initiation needs authorisation as a payment institution.
This page gives an initial view from published FCA and legislation sources. It is not an FCA determination or legal advice. Not your business model? Describe your business in MEMA Scope.
Open banking provider (AISP or PISP): frequently asked questions
Do account information providers need FCA registration?
Firms that provide only account information services need to be registered with the FCA as registered account information service providers rather than fully authorised.
Do payment initiation services need authorisation?
Payment initiation services are a payment service that requires authorisation as a payment institution.
What could change the answer for open banking providers?
Account information services alone are registered. Payment initiation needs authorisation as a payment institution. It can change depending on the answers to questions such as: Will you only read account information, and never initiate payments? Will you ever hold customer funds, even briefly? Will you rely on a regulated open banking provider and only present its service in your app?
Which FCA rules should open banking providers look at first?
Start with: Payment initiation and account information services; Perimeter guidance on the PSRs; FCA: RAISP applicants; FCA: payment institution applicants. This is an initial view from published FCA material, not an FCA determination.
What are the first steps for open banking providers?
Decide whether you do account information only or payment initiation as well. Arrange professional indemnity insurance or a comparable guarantee. Document consent, security and customer authentication arrangements. Apply for registration or authorisation as appropriate.
Businesses we check
MEMA Scope covers 32 common business models. Each page explains whether that kind of business may need FCA authorisation, the rules to look at and the routes to consider.
Consumer credit
- Do car dealers offering finance need FCA authorisation?
- Do motor finance brokers need FCA authorisation?
- Do retailers offering buy now pay later need FCA authorisation?
- Do consumer lenders need FCA authorisation?
- Do debt collectors and debt administrators need FCA authorisation?
- Do debt management and debt advice firms need FCA authorisation?
- Do credit lead generators and comparison sites need FCA authorisation?
- Do rent-to-own and vehicle leasing providers need FCA authorisation?
- Do credit brokers introducing customers to lenders need FCA authorisation?
Payments and e-money
- Do payments apps and payment processors need FCA authorisation?
- Do small payment institutions need FCA authorisation?
- Do e-money issuers and digital wallets need FCA authorisation?
- Do agents of payment institutions need FCA authorisation?
- Do money transfer and remittance businesses need FCA authorisation?
- Do marketplaces handling payments need FCA authorisation?
Insurance
Mortgages
Investments and wealth
- Do financial advisers need FCA authorisation?
- Do discretionary investment managers need FCA authorisation?
- Do investment platforms and wealth-tech firms need FCA authorisation?
- Do crowdfunding and peer-to-peer lending platforms need FCA authorisation?
- Do corporate finance boutiques need FCA authorisation?
Other regulated activities
- Do claims management companies need FCA authorisation?
- Do funeral plan providers and sellers need FCA authorisation?
- Do introducers and referral partners need FCA authorisation?
- Do international firms entering the UK need FCA authorisation?
- Do accountants and solicitors giving financial advice need FCA authorisation?
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