Decision

Advice letter: John Glen, Non-Executive Director, Open Banking Limited

Published 9 February 2026

1. BUSINESS APPOINTMENT APPLICATION: John Glen, former Paymaster General, the Cabinet Office – Paid appointment as a Non-Executive Director, Open Banking Limited

Thank you for your application, under the Government’s Business Appointment Rules for Former Ministers (the Rules), for my advice on joining Open Banking Limited as a Non-Executive Director.  

The purpose of the Rules, as you will be aware, is to protect the integrity of government and to avoid any suspicion that those who have served in government might profit improperly from that experience or that an employer might gain unfair advantage through privileged access to government. To achieve these aims, I designate conditions that former ministers must follow. 

The material information and my consideration are set out in the annex. In light of this, I consider the following conditions to be appropriate, recognising that it is your responsibility to ensure that these are demonstrably applied in practice:

• Privileged information condition – You should not draw on (disclose or use for the benefit of Open Banking Limited including its related parties and clients) any privileged information available to you from your time in ministerial office. This is an ongoing duty irrespective of the time elapsed since you left office.

• Lobbying condition – For two years from your last day in office, you should not become personally involved in lobbying the UK Government or its arm’s length bodies on behalf of Open Banking Limited (including related parties and clients). This condition does not prevent you from undertaking the duties as a Non-Executive Director as described, including having contact with the UK Government to discuss the work of Open Banking Limited on matters aligned with government policy, attending board meetings at which the UK Government or its arm’s length bodies are represented, or otherwise engaging with the UK Government at its request. However, the condition does prevent you from seeking, directly or indirectly, to influence policy, secure business/ funding or otherwise unfairly advantage Open Banking Limited (including related parties and clients), for example by making use of your contacts in government and/or ministerial office.

• Contracts and bids condition – For two years from your last day in office, you should not undertake any work with Open Banking Limited (including its related parties and clients) that involves providing advice on the terms of, or with regard to the subject matter of a bid with, or contract relating directly to the work of, the UK Government or its arm’s length bodies.

I would be grateful if you would note the following points:

• My advice is not an endorsement of the appointment.
• The advice relates solely to your previous role in government; it is separate from rules administered by other bodies such as the Office of the Registrar of Consultant Lobbyists, the Parliamentary Commissioner for Standards and the Registrar of Lords’ Interests. It is your personal responsibility to understand any other rules and regulations you may be subject to in parallel with my advice.
• By ‘privileged information’, I mean official information to which you had access as a consequence of holding office and which is not publicly available. You are also reminded that you may be subject to other duties of confidentiality, whether under the Official Secrets Act, the Ministerial Code or otherwise.
• As set out in the Rules, the lobbying restriction means that former ministers ‘should not engage in communication with government (ministers, civil servants, including special advisers, and other relevant officials/public office holders) – wherever it takes place – with a view to influencing a government decision, policy or contract award/grant in relation to their own interests or the interests of the organisation by which they are employed, or to whom they are contracted or with which they hold office’.

As soon as you take up the appointment, or if it is announced that you will do so, you are obliged under the Rules to inform my secretariat who will then publish this letter. You must also inform us if you propose to extend or otherwise change the nature of your role as, depending on the circumstances, it may be necessary for you to make a fresh application.

Yours sincerely,

Sir Laurie Magnus CBE

Independent Adviser on Ministerial Standards

2. Annex – Material information and consideration of the risks 

2.1 The role

You wish to take up a paid Non-Executive Director role with Open Banking Limited (OBL),  a UK-based company limited by guarantee which is funded and managed by the UK’s nine largest banks and building societies (“the CMA9”). 

OBL is mandated and overseen by the Competition and Markets Authority (CMA) through the legally binding Retail Banking Market Investigation Order 2017 (CMA Order), enforced by the CMA under the Enterprise Act 2022. The CMA Order requires that, through OBL, the CMA9 implement the Open Banking initiative, which necessitates the adoption of open banking to increase competition and innovation in the market. 

OBL is a temporary entity. Its function is to operate until its responsibilities are officially transferred to a permanent, statutory body. This future body will align with the Joint Regulatory Oversight Committee’s recommendations for the design of the open banking entity and the overarching vision for open banking.

As a Non-Executive Director, you will, amongst other things, be responsible for monitoring OBL’s strategic advancement to ensure adherence to the CMA Order requirements. This includes building and maintaining relationships with key stakeholders, such as the CMA and other regulators, and collaborating with and influencing these stakeholders to develop and review the strategy for OBL’s transition to a future entity.

I note that your income from this appointment will be used to support Salisbury 800, an initiative to celebrate the foundation of Salisbury by Royal Charter in 1227.

2.2 Dealings in office

You said that you were neither involved in any policy, regulatory or commercial decisions specific to OBL, nor had access to any information that could grant the company an unfair advantage.

2.3 Departmental assessment

The Cabinet Office confirmed the details you provided and recommended the standard conditions. 

2.4 My consideration of the risks 

As Paymaster General, you will have had access to general privileged information that could be of interest to OBL. However, you made no policy, regulatory or commercial decisions specific to OBL, and the Cabinet Office has no concerns over your access to privileged information. 

You previously held the role of Economic Secretary until July 2022, followed by Chief Secretary to the Treasury until November 2023, which would have provided significant insight into the sector in which OBL operates. Given that more than two years have passed since you last had access to privileged information, these previous roles are outside the scope of the Rules. Further, the Rules do not prohibit you from utilising your general skills, knowledge, experience, and any publicly available information. To that end, I consider the risks appropriately mitigated by the standard conditions. 

As a company mandated and overseen by the UK government, operating in financial services, OBL has a clear interest in government policy. Moreover, its transitional status is subject to ongoing government decision-making as its future is yet to be determined. Your role, as described, gives rise to a risk that you could provide unfair access to government  and influence the terms of OBL’s transition arrangements.

The risk here is, however, somewhat limited by OBL’s existing relationship with government under an established framework, as it is not contrary to the Rules to engage with government if contact is through official channels or when initiated by government itself. It is significant that your proposed employer has provided written confirmation of its agreement to comply with the advice and the separation of your role from lobbying. Further, given your role in assisting OBL to comply with the CMA Order, I find that it would be improper to preclude your engagement with government in these situations. Therefore, to mitigate the risk of lobbying, particularly in relation to influencing transitional arrangements, I have applied an amended lobbying condition. This condition does not prevent you from fulfilling your duties as described.