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UK’s Open Banking Limited launches consultation on the MLA for commercial VRPs

Ellie Duncan
31 Jan 2025

Open Banking Limited (OBL) in the UK has launched a public consultation on the multilateral agreement (MLA) for commercial variable recurring payments (cVRPs).

OBL has published the consultation alongside draft documents that explain the background to cVRPs, outline what the MLA is and its purpose, and pose the questions it is seeking responses to in this consultation.

Among the key questions being posed are whether the MLA “enhances and fosters inclusion and increased competition”, and if it provides flexibility to foster different market participants being able to offer or use cVRPs.

It is also asking whether the information provided to customers and other elements of the cVRP design provide “adequate protections” to customers.

The industry is being invited to provide written responses by 28 February.

OBL and Pay.UK have been working with industry participants to “define” the policies that determine how cVRPs will work and, alongside the legal drafting prepared by external legal advisors Addleshaw Goddard, this has produced the series of documents comprising the MLA that is now being consulted on.

Once the participation agreement, rulebook and schedules that make up the MLA have been agreed upon, OBL said it expects a series of operational guidelines will be produced to “aid” industry participants.

In a statement, OBL said that the aim of the consultation “is to ensure the MLA documents meet the requirements of the cVRP product and that there are no material errors, deficiencies or other issues in the content of these documents that would otherwise lead to poor delivery or poor customer experiences of cVRPs, which would harm their adoption”.

A commercial model for VRPs remains in development and has not been included in the MLA at this stage, although OBL anticipates that this will be added to the MLA separately, once the consultation has concluded.

Last week, the Financial Conduct Authority and Payment Systems Regulator announced the creation of a new independent central operator for VRPs, as part of the next steps for Open Banking in the UK.

They also stated that they expect to see “significant progress” in 2025, which will see live services available for consumers to make recurring payments to.