Report

OBL launches public consultation on the MLA for commercial variable recurring payments

30 January 2025

OBL is pleased to publish Commercial Variable Recurring Payments (cVRP), the public consultation on the cVRP Multilateral Agreement (MLA).

This paper is published alongside the draft documents that together make up the MLA for cVRPs. Here, we explain the background to cVRPs, outline what the MLA is and its purpose, and pose the questions we are seeking responses to in this consultation.

The aim of this 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.

We ask that you look at the MLA documents that are published alongside this document, and provide your feedback. You can download the consultation here.

Download the consultation

Read here

We welcome written responses from the industry by close of business 28 February 2025. You can complete your responses to the consultation using our online survey, or email your response to us.

Multilateral Agreement
Open Banking Limited (OBL) and Pay.UK have been working with different industry Participants to define the policies that determine how cVRPs will operate. This work, alongside the legal drafting prepared by our external legal advisors, Addleshaw Goddard, has produced the series of documents comprising the MLA on which we are now consulting.

The MLA is made up of a Participation Agreement, a Rulebook, and Schedules to those rules. After these have been agreed, we anticipate a series of operational guides will be produced to aid industry participants.

The Participation Agreement is the contract which Participants will need to enter into in order to take part in the cVRP system. It sets out a contractual relationship between the Operator and each individual Participant. Participants can either be PISPs, or ASPSPs. It also allows for Participants to act in both roles.

The Rulebook is the detailed set of rules that all Participants, and the Operator, need to adhere to.

The premise of cVRPs is that there is a commercial model underpinning the set-up of cVRPs on customer accounts and any payments initiated under those cVRPs. This means PISPs pay ASPSPs for access to those APIs.

The commercial model remains in development and is not included in the MLA at this time. It is envisaged that the commercial model will be added to the MLA separately after this consultation has concluded.

Consultation questions
We are asking for feedback on the MLA documents. These are published alongside this document.
Key questions that we are seeking input on, and feedback from you:

  1. Do you agree that the MLA enhances and fosters inclusion and increased competition? Please provide reasons for your answer.
  2. Do you agree that the MLA provides flexibility to foster different market Participants being able to offer / use cVRPs? Please provide reasons for your answer.
  3. Do you agree the MLA provides the Operator with adequate tools to manage Participant compliance? Please provide reasons for your answer.
  4. Do you agree that the information provided to customers and other elements of the cVRP design provides adequate protections to customers? Please provide reasons for your answer.
  5. Do you agree the rules and requirements in the MLA are adequate to ensure a competitive and attractive product for beneficiaries such as billers and merchants? Please provide reasons for your answer.
  6. Do you agree that the key aims of the MLA to build consistency in approach for the benefit of Participants, customers and beneficiaries are achieved? If not, can you provide specific examples where this is not achieved and reasons for your answer.

Please submit any written responses you may have before close on 28 February 2025 via email or our survey. We will consider your comments when preparing our response to this consultation.

We reserve the right to make all non-confidential responses to this consultation available for public inspection.

Confidentiality notice
We will not regard a standard confidentiality statement in an email message as a request for non-disclosure. If you want to claim commercial-in-confidence protection over any specific items in your response or your entire response, you must identify those specific items which you claim to be confidential.

We will not publish any responses which include information marked as confidential, unless we are specifically required to do so by any applicable laws or regulations or by any competent authority. We will consult with you if we receive such a requirement, to the extent not prevented from doing so by any applicable laws or regulations or by any competent authority.

We take our data protection responsibilities seriously and will process any personal data that you provide to us in accordance with the Data Protection Act 2018, and the General Data Protection Regulation, where relevant.