Ozone API has launched a dedicated commercial Variable Recurring Payments product for UK banks and payment service providers that sit outside the CMA9 mandatory compliance group. The company says any institution can go live with a fully OBL 4.0-compliant cVRP infrastructure in 8 to 10 weeks via its Ozone Connect integration layer, with no internal build required and no need for a dedicated standards-monitoring team.
The timing is deliberate. The UK Payments Initiative, a 31-organisation consortium that includes NatWest Group, Nationwide, Monzo, Mastercard Open Banking Services, GoCardless, TrueLayer, Yapily and Plaid, is operational in 2026 and has positioned itself as the first new UK payment scheme since 2008. Visa A2A is simultaneously onboarding its first wave of financial institution partners. Both initiatives require OBL 4.0 in production as a prerequisite for participation.
The compliance gap non-CMA9 banks face

Only the nine largest UK banks are mandated to implement OBL 4.0. Every other UK bank and PSP faces a voluntary decision. In practice, an internal implementation typically takes six to twelve months, followed by ongoing engineering effort to track and apply successive updates as the standard evolves. Ozone API’s proposition is that it removes that overhead entirely by managing the standard lifecycle on behalf of the institution.
The technical scope covered includes all VRP API endpoints, the FAPI 1.0 Advanced security profile, OAuth 2.0 and OpenID Connect, automated consent management with full audit logging, a multi-environment developer sandbox with synthetic data, and certificate and credential management. Standards updates are applied automatically once an institution is live. The product is available as cloud SaaS or on-premise and carries ISO 27001:2022 and SOC 2 Type 2 certification.
Current live use cases cited by the company include subscription management as a card-on-file replacement, utility bill payments, flexible loan repayments, and tax and local authority payments. E-commerce one-click checkout sits on the roadmap for 2027, aligned with the National Payments Vision.
Huw Davies, co-founder and chief executive of Ozone API, said the commercial window is already open. “UKPI is live, Visa A2A is onboarding, and the use cases are real today. The opportunity exists for banks to monetise open banking payments, but only if they move. Otherwise we risk a two-tier market where only the CMA9 banks are participating in cVRP.”
Market context and competitive read-across
Ozone API’s claim to authority rests on its founding heritage: the company was set up by architects of the original UK Open Banking standard and serves as the reference implementation for that standard. It reports more than 100 financial institutions live on its platform globally, though it has not named non-CMA9 UK launch customers for this specific product.
The broader competitive dynamic is significant. As cVRP moves from a regulatory compliance exercise into a commercial payment rail, the ecosystem is bifurcating. CMA9 institutions have the compliance infrastructure already in production and are the natural first movers for UKPI and Visa A2A revenue sharing. Non-CMA9 banks risk being structurally excluded from cVRP revenue flows unless they close the infrastructure gap quickly. Ozone API’s product is positioned as the fastest route to closing it, but institutions will want to weigh the vendor-dependency trade-off against the cost and delay of an internal build.
For the UK open banking market more broadly, the emergence of viable commercial cVRP schemes marks a transition that policymakers and the Payment Systems Regulator have long anticipated: from mandatory compliance plumbing toward a genuine A2A payments alternative to card rails. The pace at which non-CMA9 institutions adopt OBL 4.0 will determine whether that transition creates a genuinely competitive multi-participant scheme or consolidates around the largest incumbents.
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