Brexit
Yapily's recommendations and information about the upcoming Brexit changes.
The upcoming Brexit deadline of the 31st December means that there are numerous changes required by each Institution
, Yapily and our clients.
Key Changes
- Every
Institution
with theGB
country tag will continue to work with no changes required until July 2021 - Every
Institution
with a non-GB
country tag will cease to work using a UK registration after December 31st - For SafeConnect Customers: Yapily's temporary Fintecture eIDAS registration will be used for all European Institutions from January 1st 2021
- For SafeConnect Customers: Yapily is expected to obtain its Lithuanian eIDAS registration which will be used in the UK and to passport into all existing and future European countries in Q1 2021
Our plans
December 2020
Yapily is currently going through the process of migrating and testing the Fintecture eIDAS registration with each European Institution
. Yapily plans to start migrating SafeConnect customers before
the end of 2020.
January 2021
Yapily plans to have migrated all SafeConnect customer applications to use the Fintecture registration for banks in Europe.
Q1 2021
For SafeConnect Customers: Yapily anticipates that it will receive the go ahead to passport into each of the European countries that it has Institution
integrations for in Q1 2021. As each
country is approved, Yapily will be testing the registrations for each Institution
internally to ensure that it can seamlessly switch SafeConnect customers over to the new certificate.
While certain countries may be approved, tested and ready earlier than others, Yapily's plan is to wait for all major countries to be ready for passporting using our Lithuanian registration. This is so that Yapily can minimalise the number of code changes required for its SafeConnect clients.
July 2021
This is the deadline for when each Institution
with the GB
tag must stop using the legacy certificates (transport
+ signing
) and be using the OBWAC
+ OBSEAL
certificates. For direct
customers, see the Registration details for more information on the required changes. For SafeConnect, Yapily plans to do this for you before the deadline.
Unlike the registration changes, this change will not result in losing any consents.
Changes to Institutions
UK Institutions
There are no required changes for applications that contain GB
-only Institutions
until July 2021. From July 2021, Institutions
in the UK will stop accepting the Open Banking legacy
certificates (transport
+ signing
). If you are a direct customer check the required steps to prepare for this change. If you are a SafeConnect customer, Yapily
will make this change for you before the deadline.
European Institutions
From January 1st 2021, every European Institution
will require a European-based eIDAS certificates for continued Open Banking connectivity. From this date, each Institution
will no longer
accept UK-based eIDAS certificates due to the impending changes regarding Brexit.
Special Cases
- PayPal: PayPal account holders can be both UK and non-UK. As a result, we are introducing a new
Institution
paypal-eu
in order to split UK and European accounts. From 1st January, you will require both integrations if you have PayPal customers in both the UK and across Europe. - Revolut: We anticipate Revolut to require a similar solution to PayPal
- AMEX: We also expect the AMEX integration to require a similar solution to PayPal
Changes you need to make
There are a different number of things to bear in mind depending on whether you are a direct customer or a SafeConnect customer:
Direct Customers
Registration
transport
+ signing
). Before this deadline, you will need to generate a new key pair of OBWAC
+ OBSEAL
certificates in the Open Banking Directory under your existing organisation and upload them to them
to the Yapily Dashboard certificate store. For each Institution
, you will then need to edit the credentials in the Institutions tab of your
appropriate application(s) in the Yapily Dashboard and update the Key Id
, Signing Certificate
and Transport Certificate
SafeConnect Customers
Registration
- Yapily will be switching every non-
GB
Institution
to use the Fintecture license before January 1st 2021. If you haveInstitutions
in both Europe and the UK, this will mean using the Fintecture registration in Europe and the SafeConnect registration in the UK. For yourInstitutions
in Europe that will be moved to the Fintecture registration, this will result in some disruption for your consents so you will need to prepare accordingly - Once Yapily's Lithuanian registration is complete and can passport into all the European countries, Yapily will revert to using one registration for every
Institution
. You will then be able to revert to using only the SafeConnect guidelines for eachGB
and non-GB
Institution
. This change will once again result in some disruption for your consents
Consent Guidelines
Up until now, the redirectUrl
has been set to https://auth.yapily.com/
but for all Fintecture registrations (every non-GB
bank after 1st January), the
redirectUrl
will be https://auth.fintecture.com/
. Inline with this change, the SafeConnect guidelines will have to be adjusted so that the existing consent screen containing the
SafeConnect logo, T&Cs and name when Institution.countries
array contains the countryCode2=GB
. For each Institution
that has a countryCode
of any
other value, you will need to replace the SafeConnect wording to "Fintecture" and use the following T&Cs and logos:
- Fintecture T&Cs
- Fintecture Privacy Policy
- Logo Dark Blue
- Logo White
Consent Guidelines Example
Non-UK banks (before Brexit):
What happens next
SafeConnect will ask to securely authorise and execute a payment from your bank and provide the payment details to [YOUR APP].
Who is SafeConnect
SafeConnect Ltd is authorised and regulated by the Financial Conduct Authority under the Payment Service Regulations 2018 for Account Information and Payment Initiation Services.
Non-UK banks (after Brexit):
What happens next
Fintecture will ask to securely authorise and execute a payment from your bank and provide the payment details to [YOUR APP].
Who is Fintecture
Fintecture SAS is registered with the ACPR under the number 17248 for the provision of Account Information and Payment Initiation Services.
If you are a GB
-only customer, then these changes do not apply.
Customer Impact
Regardless of whether you are a direct customer and are currently in the process of obtaining your own eIDAS license or you are a SafeConnect customer, obtaining a Brexit-ready registration to accommodate for European banks will have some implications for the consents within your application(s).
AIS
Once you change to your Brexit-ready registration for each Institution
, you will lose all AIS consents for each Institution
. You will have to request the user's to authorise their consents for
your applications again.
PIS
Once you change to your Brexit-ready registration for each Institution
, you will lose all PIS consents for each Institution
. While the impact is less significant for PIS since you must obtain a
user authorisation for every payment, you will no longer be able to check on the status of payments.
Make sure you leave enough time to switch over to your European banks so that you are able to verify that all payments transition from PENDING
to COMPLETED
.