Open Banking Limited (OBL) has published updated Q&As clarifying when variable recurring payments (VRPs) can be used for “sweeping” under the Competition and Markets Authority’s Retail Banking Market Investigation Order 2017, focusing on destination accounts for which the nine mandated banks (the CMA9) must provide sweeping access. The March 2026 update reflects the CMA’s 3 December 2025 letter on sweeping to alternative forms of credit that closely compete with overdrafts and responds to interpretation queries raised by market participants. The Q&As set out destination account criteria and key exclusions. In-scope e-money destination accounts should have current-account features and be used and marketed as a current-account substitute, while cash savings accounts are within scope where they pay a higher interest rate than the source current account and are marketed as savings products, with PISPs expected to check the rate differential. Transfers into Buy Now Pay Later accounts are described as unlikely to meet the sweeping definition, and sweeping to repay credit may only be mandated where the destination credit account resembles an overdraft through a revolving facility with no fixed repayment schedule; one-off loans, hire purchase or similar single-purchase finance, and asset-secured lending are excluded. Credit card repayments are included, but charge cards are excluded. The guidance also indicates that collection accounts can be used where the ultimate beneficiary is the same customer, destination accounts do not need unique sort code and account number details, and accounts must not be used as an automatic mechanism to sweep into investments, with any onward transfer outside scope needing to be independent of the sweep. Where a CMA9 bank and a PISP disagree on whether a use case is sweeping, OBL sets an escalation route from bilateral discussions to OBL investigation and a provisional decision in consultation with the Open Banking Trustee, with the option for a formal Trustee decision that can confirm whether mandated sweeping access applies and which OBL will publish. The Q&As are positioned as a live document to be updated as market and regulatory developments occur, and they note that commercial arrangements for VRPs outside sweeping are not restricted by the CMA clarification or the Q&As.
Open Banking Limited 2026-03-16
Open Banking Limited updates VRP sweeping guidance to reflect CMA position on overdraft-like credit repayments
Open Banking Limited has issued updated Q&As clarifying the use of variable recurring payments (VRPs) for "sweeping" under the Competition and Markets Authority’s Retail Banking Market Investigation Order 2017. The guidance specifies criteria for destination accounts, exclusions, and escalation routes for disputes between CMA9 banks and PISPs. The Q&As will be updated as market and regulatory developments occur, with commercial arrangements for VRPs outside sweeping remaining unrestricted.