OB OB Open Banking Module
OB-A OB-A Introduction
OB-A.1 OB-A.1 Purpose
OB-A.1.1
This Module sets out the Central Bank of Bahrain's (CBB's) Directive relevant to
ancillary service providers providing either or both of the following regulated services defined in the Ancillary Services Authorisation Module of the CBB Rulebook Volume 5 in the Kingdom of Bahrain:(a) the provision ofaccount information services; or(b) the provision ofpayment initiation services. Added: December 2018OB-A.1.2
This Module should be read in conjunction with the requirements in other parts of the CBB Rulebook, Volume 5, applicable to
specialised licensees particularly:(c) Ancillary Service Providers Authorisation Module;(d) Principles of Business Module;(e) General Requirements Module;(f) CBB Reporting Requirements Module(g) Auditors and Accounting Standards Module;(h) Financial Crime Module; and(i) Enforcement Module.Added: December 2018Legal Basis
OB-A.1.3
This Module contains the CBB's Directive (as amended from time to time) applicable to
ancillary services providers undertakingaccount information services orpayment initiation services , and is issued under the powers available to the CBB under Article 38 of the CBB Law.Added: December 2018OB-A.1.4
For an explanation of the CBB's rule-making powers and different regulatory instruments, see Section UG-1.1.
Added: December 2018OB-A.2 OB-A.2 Module History
OB-A.2.1
This Module was first issued in November 2018. It is numbered as version 01. All subsequent changes to this Module are annotated with a sequential version number. UG-3 provides further details on Rulebook maintenance and version control.
Added: December 2018OB-A.2.2
A list of recent changes made to this Module is provided below:
Module Ref. Change Date Description of Changes OB-1.1.12 07/2021 Amended Paragraph on PISPs procedures.. OB-1.1.13 07/2021 Amended Paragraph on AISPs procedures.. OB-2.1.1 07/2021 Amended Paragraph on AISPs and PISPs framework contract. OB-2.1.5 07/2021 Added a new Paragraph on customer consent. OB-2.1.6 07/2021 Added A new Paragraph on data access. OB-2.2.1 07/2021 Amended Paragraph on authentication. OB-2.2.2 07/2021 Deleted Paragraph. OB-2.2.3 07/2021 Deleted Paragraph. OB-2.2.4 07/2021 Deleted Paragraph. OB-2.2.5 07/2021 Deleted Paragraph. OB-2.2.6 07/2021 Deleted Paragraph. OB-2.3.8 07/2021 Amended Paragraph on fees and charges. OB-2.4.1 07/2021 Amended Paragraph on adherence to guidelines. OB-2.4.2 07/2021 Amended Paragraph on compliance. OB-2.4.3 07/2021 Added a new Paragraph on technology solutions provided. OB-2.4.3 01/2024 Amended Paragraph on technology solutions provided. OB-B.1.1 05/2024 Amended introduction Paragraph. OB-2.4.1 05/2024 Amended Paragraph on technology related requirements. OB-B OB-B Scope of Application
OB-B.1 OB-B.1 Introduction
OB-B.1.1
The provision of
account information services andpayment initiation services entails obtaining access tocustomer accounts (the term ‘customer’ refers to both natural and legal persons) through 'application program interfaces' (APIs) with licensees maintainingcustomer accounts includeconventional retail bank licensees ,Islamic retail bank licensees financing companies and PSPs operating electronic wallets, (referred to in this Module as "licensees maintainingcustomer accounts"). Given the nature of risks inherent in online activities, theancillary service providers undertaking such activities will be subject to strict regulatory standards to ensure the integrity and safety ofcustomer data, the APIs,customer on boarding process, authentication process, communication sessions, process for tracking of security incidents and associated standards of dealing with thecustomers while undertaking this activity.Amended: September 2024
Added: December 2018OB-1 OB-1 Risks, Systems and Controls
OB-1.1 OB-1.1 Risks, Systems and Controls
Internal Controls
OB-1.1.1
The Board of Directors or equivalent authority must take responsibility for the establishment and oversight of effective risk management and internal controls.
Added: December 2018OB-1.1.2
Account information service providers (AISPs) and payment initiation service providers (PISPs) must use technology solutions which are capable of interfacing with software and systems used by licensees maintaining
customer accounts with no material modifications to their systems.Added: December 2018OB-1.1.3
Consistent with Module PB: Principles of Business, Paragraph, PB-1.1.10, AISPs and PISPs must establish adequate internal controls to safeguard the business, its
customers and licensees to which they have online access to.Added: December 2018OB-1.1.4
The internal controls must include, but not be limited to, those relating to the following:
(a) The development and or acquisition of the technology solutions to conduct the activity;(b) Testing of the solutions and application program interfaces;(c) Standards of communication and access and security of communication sessions;(d) Safe authentication of the users;(e) Processes and measures that protectcustomer data confidentiality and personalised security credentials consistent with Law No. 30 of 2018, Personal Data Protection Law (PDPL) issued on 12 July 2018;(f) Tools and measures to prevent frauds and errors;(g) Security policy;(h) Information security testing including web applications testing, configuration reviews, penetration testing and smart device application testing(i) Risk management controls;(j) Prevention of anti-money laundering (AML) and combating terrorist financing (CTF);(k) Record keeping and audit trails; and(l) Operational and financial controls.Added: December 2018Operational Risks
OB-1.1.5
AISPs and PISPs must document the process by which they identify, prioritise and manage their operational risks.
Added: December 2018OB-1.1.6
Operational risk in AISPs' and PISPs' activities include the risk of loss of confidential
customer data, financial loss or reputational loss resulting from inadequate or failed internal processes, people, technology and systems, or from external events including risks of internal and external frauds and cyber threats. In assessing potential operational risk, the following are some of the factors that may affect the licensee's risk exposure:(a) Lack of governance, board and management oversight;(b) Inadequate internal controls;(c) Insufficient transaction monitoring;(d) Failure of information technology through breakdown, incompatibility of legacy systems and poor scalability, poor security, etc.;(e) Failure or insufficient cyber and information security controls;(f) Failure of processes and procedures;(g) Internal and external fraud;(h) Legal risks;(i) Outsourcing risk;(j) Business continuity and disaster recovery; and(k) Reputational risks.Added: December 2018OB-1.1.7
AISPs and PISPs must establish comprehensive procedures for monitoring, handling and following up on security and fraud incidents and related
customer complaints including but not limited to the following:a) organisational measures and tools for the prevention of such incidents;b) details of the individual(s) and bodies responsible for assistingcustomers in cases of the incidents and technical issues and/or claim management;c) reporting lines in cases of such incidents;d) the contact point forcustomers , including a name and email address;e) the procedures for the reporting of incidents, including the communication of these reports to internal or external bodies, including notification of major incidents to national competent authorities; andf) the monitoring tools used and the follow-up measures and procedures in place to mitigate security and fraud risks.Added: December 2018OB-1.1.8
AISPs and PISPs must maintain an up to date security policy document containing the following information:
a) A detailed documentation of the technology architecture and of the systems and the network elements providing:i. a description of the business IT systems supporting the business activities;ii. the type of authorised connections from outside, such as with partners, service providers, entities of the group and employees working remotely, including the rationale for such connections;iii. for each of the connections, the logical security measures and mechanisms in place, specifying the control the licensee will have over such access as well as the nature and frequency of each control,iv. process for the opening/closing of communication lines, and description of security equipment configuration, generation of keys or client authentication certificates, system monitoring, authentication, confidentiality of communication, intrusion detection, antivirus systems and logs;b) the logical security measures and mechanisms that govern the internal access to IT systems;c) the physical security measures and mechanisms of the premises and the data centre of the licensee, such as access controls and environmental security;d) the security of the account information and payment initiation processes, which should include:i. thecustomer authentication procedures used for both consultative and transactional access, and for all underlying payment instruments;ii. an explanation of how safe delivery of tokens to the legitimatecustomer ; andiii. a description of the integrity of authentication factors, tokens and online and mobile applications at the time of both initial enrolment and renewal.Added: December 2018OB-1.1.9
AISPs and PISPs must ensure they have an up to date business continuity plan and arrangements consisting of the following information:
a) a business impact analysis, including the business processes and recovery objectives, such as recovery time objectives, recovery point objectives and protected assets;b) the identification of the back-up site, access to IT infrastructure, and the key software and data to recover from a disaster or disruption;c) an explanation of how the licensee will deal with significant continuity events and disruptions, such as the failure of key systems; the loss of key data; the inaccessibility of the premises; and the loss of key persons; andd) the frequency with which the licensee intends to test the business continuity and disaster recovery plans, including how the results of the testing will be recorded.Added: December 2018OB-1.1.10
AISPs and PISPs must appoint a third party specialist to conduct vulnerability assessments against cyber-attacks and penetration testing on the specific API security standards every 6 months. The specialist's report must be submitted to the CBB, along with the licensee's related action plan to resolve any issues identified. All relevant threat profiles referenced in the security standards including the risk of social engineering must be considered for the reviews.
Added: December 2018OB-1.1.11
AISPs and PISPs must ensure that their overall systems and controls including but not limited to the business continuity, disaster recovery, information security testing, web-applications testing, smart device application testing, and cyber resilience are evaluated and independently tested by an external consultant:
a) initially upon implementation of this Module;b) when there are any material changes to the systems and controls; andc) at least once every 3 years.Added: December 2018OB-1.1.12
A PISP must establish procedures to ensure:
(a) that it will not store acustomer's personalised security credentials, such as customer’s KYC and biometric information and that such data are:i. not accessible to other parties, with the exception of the issuer of the credentials; andii. transmitted through safe and efficient channels;(b) that any other information about acustomer is not provided to any person except a payee, and is provided to the payee only with thecustomer's explicit consent;(c) that each time a PISP initiates a payment order on behalf of itscustomer , the PISP identifies itself to the licensee with whom the customer maintains the account in a secure way;(d) [This Sub-paragraph was deleted in July 2021];(e) that it will not access, use or store any information for any purpose except for the provision of a payment initiation service explicitly requested by a payer, however, it may store payment details initiated by thecustomer such as payment amounts, payment accounts, payment reference number, payment execution dates, time and payee’s IBAN number;(f) that it cannot and does not change the amount, the payee or any other feature of a transaction notified to it by thecustomer .(g) that any data accessed and stored is encrypted in transit and at rest and, must not be accessible to any unauthorised person within thelicensee’s organisation.Amended: July 2021
Added: December 2018OB-1.1.13
An AISP must establish procedures to ensure:
(a) it does not provideaccount information services without thecustomer's explicit consent;(b) that it will not store thecustomer's personalised security credentials such ascustomer ’s KYC and biometric information and that such data are:i. not accessible to other parties, with the exception of the issuer of the credentials; andii. transmitted through safe and efficient channels;(c) for each communication session, communicate securely with licensee and thecustomer in accordance with the regulatory requirements of this Module;(d) that it does not access any information other than information from designated accounts;(e) it will not access, use or store any information for any purpose except for the provision of the account information service explicitly requested by thecustomer ;(f) that any data accessed and stored is encrypted in transit and at rest and, must not be accessible to any unauthorised person within the licensee’s organisation; and(g) thatcustomer information accessed must not be stored in a form which permits identification ofcustomer once thecustomer consent is withdrawn.Amended: July 2021
Added: December 2018OB-2 OB-2 Operating Rules
OB-2.1 OB-2.1 Framework Contracts
Legal arrangement and transparency
OB-2.1.1
AISPs and PISPs must establish a framework contract (a legal arrangement) with the
customer prior to providing AIS or PIS services. The framework contract must provide the information set forth below that are relevant to the services they provide:(a) The following information about the service and the provider:i. the name, address and contact details of the PISP or AISP as the case may be;ii. a description of the main characteristics of the service to be provided;iii. the information or unique identifier that must be provided by thecustomer in order for a payment order to be properly initiated or executed;(b) the form and procedures for giving consent to provide account information service, the initiation of a payment order and for the withdrawal of consent;(c) provisions regarding the time of receipt of a payment order and the cut-off time, if any, established by the licensee and the maximum execution time for the payment services to be provided;(d) whether spending limits for the use of apayment instrument may be agreed;(e) the detail of all fees and charges payable by thecustomer to the PISP/AISP, including those connected to the manner in and frequency with which information is provided or made available and, where applicable, a breakdown of the amounts of any charges;(f) the means of communication agreed between the parties for the transmission of information or notifications under this Module including, where relevant, any technical requirements for thecustomer 's equipment and software for receipt of the information or notifications;(g) The terms under which thecustomer may opt out from the use of thepayment instrument ;(h) explicit consents required for generic marketing promotions by the PISP/AISP; and(i) the terms of the framework contract and information.(j) The following information about safeguards and corrective measures in compliance with PDPL:i. where relevant, a description of the steps that thecustomer is to take in order to keep safe apayment instrument and how to notify the PISP/AISP for the purposes of obligations of thecustomer in relation to loss, theft, misappropriation, unauthorised use of thepayment instruments and personalised security credentials;ii. the secure procedures, by which the PISP/AISP will contact thecustomer in the event of suspected or actual fraud or security threats;iii. the conditions under which the PISP/AISP stops or prevents the use of apayment instrument ;iv. thecustomer's liability, (payer or payee's liability for unauthorized payment transactions), including details of any limits on such liability;v. how and within what period of time thecustomer is to notify the licensee maintainingcustomer account of any unauthorised or incorrectly initiated or executed payment transaction, and liability, if any for unauthorised payment transactions falling on the licensee maintainingcustomer account for execution of unauthorised payment transactions);vi. liability, if any, in the event of initiation or execution or non-execution or defective or late execution of payment transactions;vii. liability of parties in the event of a cyber-attack and loss of sensitive data; andviii. the conditions for any refunds for payment transactions initiated by or through a payee.(k) The following information about changes to and termination of the framework contract:i. the time given to thecustomer to review and accept any proposed changes; which under no circumstances, shall be less than 10 calendar days;ii. the proposed terms under which thecustomer will be deemed to have accepted changes to the framework contract in accordance, unless they notify the service provider that they do not accept such changes before the proposed date of their entry into force;iii. the duration of the framework contract;iv. where relevant, the right of thecustomer to terminate the framework contract and any agreements relating to.(l) The following information about redress:i. any contractual clause on the law applicable to the framework contract;ii. the customer complaint procedures and the availability of alternative dispute resolution procedures for thecustomer and the methods for having access to them; andiii. the name/title and contact number of the person designated to handle any queries or complaints.Amended: July 2021
Added: December 2018OB-2.1.2
The information specified in Paragraph OB-2.1.1 must be provided to the
customer free of charge before initiation of service.Added: December 2018OB-2.1.3
(a) A framework contract may provide for the PISP to have the right to stop the use of apayment instrument on reasonable ground relating to: the security of thepayment instrument ; or(b) the suspected unauthorised or fraudulent use of thepayment instrument .Added: December 2018OB-2.1.4
AISPs and PISPs must agree the basis, the time period and the manner in which the information on its intention to stop the use of the
payment instrument will be provided to thecustomer and to the relevant licensees maintainingcustomer accounts.Added: December 2018OB-2.1.5
AISPs must allow
customers to provide consent for accessing their account information for a duration of up to 12 months.Added: July 2021OB-2.1.6
AISPs must allow their
customers to choose the nature and type of data to be collected or accessed and used by the AISP for the purpose of providing the services.Added: July 2021OB-2.2 OB-2.2 Standards for Authentication and Communication
Secure authentication
OB-2.2.1
AISPs and PISPs must have in place a 2-factor authentication process to prevent unauthorised access.
(a) [This sub-paragraph was deleted in July 2021];(b) [This sub-paragraph was deleted in July 2021];(c) [This sub-paragraph was deleted in July 2021].Amended: July 2021
Added: December 2018OB-2.2.2
[This Paragraph was deleted in July 2021].
Deleted: July 2021
Added: December 2018OB-2.2.3
[This Paragraph was deleted in July 2021].
(a) [This sub-paragraph was deleted in July 2021];(b) [This sub-paragraph was deleted in July 2021];(c) [This sub-paragraph was deleted in July 2021];(d) [This sub-paragraph was deleted in July 2021].Deleted: July 2021
Added: December 2018Independence of elements of strong authentication
OB-2.2.4
[This Paragraph was deleted in July 2021].
(a) [This sub-paragraph was deleted in July 2021];(b) [This sub-paragraph was deleted in July 2021];(c) [This sub-paragraph was deleted in July 2021].Deleted: July 2021
Added: December 2018OB-2.2.5
[This Paragraph was deleted in July 2021].
Deleted: July 2021
Added: December 2018OB-2.2.6
[This Paragraph was deleted in July 2021].
(a) [This sub-paragraph was deleted in July 2021];(b) [This sub-paragraph was deleted in July 2021].Deleted: July 2021
Added: December 2018Confidentiality and Integrity of Personalised Security Credentials
OB-2.2.7
AISPs and PISPs must ensure that the creation of personalised security credentials is performed in a secure environment. AISPs and PISPs must mitigate the risks of unauthorised use of the personalised security credentials and of the authentication devices and software due to their loss, theft or copying before their delivery to the payer.
Added: December 2018OB-2.2.8
AISPs and PISPs must ensure the confidentiality and integrity of the personalised security credentials of the
customer , including authentication codes, during all phases of authentication including display and transmission.Added: December 2018OB-2.2.9
For the purpose of Paragraph OB-2.2.8, AISPs and PISPs must ensure that each of the following requirements are met:
(a) personalised security credentials are masked when displayed and not readable in their full extent when input by thecustomer during the authentication;(b) personalised security credentials in data format, as well as cryptographic materials related to the encryption of the personalised security credentials are not stored in plaintext;(c) secret cryptographic material is protected from unauthorised disclosure.Added: December 2018OB-2.2.10
PISPs and AISPs must ensure that only the
customer is associated with the personalised security credentials, with the authentication devices and the software in a secure manner.Added: December 2018Security of Communication Sessions
OB-2.2.11
AISPs and PISPs must ensure that any communication session established with the
customer , and other entities, including merchants, relies on each of the following:(a) a unique identifier of the session;(b) security mechanisms for the detailed logging of the transaction, including transaction number, timestamps and all relevant transaction data; and(c) timestamps which shall be based on a unified time-reference system and which shall be synchronised according to an official time signal.Added: December 2018OB-2.2.12
AISPs and PISPs must rely on qualified certificates for electronic seals for identification of the different parties for communication between parties.
Added: December 2018OB-2.2.13
AISPs and PISPs must ensure that the risks against misdirection of communication to unauthorised parties in mobile applications and other
customers ' interfaces offering electronic payment services are effectively mitigated.Added: December 2018OB-2.2.14
AISPs and PISPs must ensure that, when exchanging data via the internet, secure encryption, using strong and widely recognised encryption techniques, is applied between the communicating parties throughout the respective communication session in order to safeguard the confidentiality and the integrity of the data, using strong and widely recognised encryption techniques.
Added: December 2018OB-2.2.15
AISPs and PISPs must keep the access sessions offered by the licensee maintaining
customer account, as short as possible and they shall actively terminate the session with the relevant licensee maintaining customer account as soon as the requested action has been completed.Added: December 2018OB-2.2.16
When maintaining parallel network sessions with the bank licensees, AISPs and PISPs must ensure that those sessions are securely linked to relevant sessions established in order to prevent the possibility that any message or information communicated between them could be misrouted.
Added: December 2018OB-2.2.17
AISPs and PISPs, with the licensee maintaining
customer accounts must include unambiguous reference to each of the following items:(a) thecustomer or users and the corresponding communication session in order to distinguish several requests from the samecustomer or users;(b) for payment initiation services, the uniquely identified payment transaction initiated;(c) For confirmation on the availability of funds, the uniquely identified request related to the amount necessary for the execution of transaction.Added: December 2018OB-2.2.18
AISPs and PISPs must ensure that where they communicate personalised security credentials and authentication codes, these are not readable by any staff at any time. In case of loss of confidentiality of personalised security credentials under their sphere of competence, PISPs and AISPs must inform without undue delay the
customer associated with them and the issuer of the personalised security credentials.Added: December 2018OB-2.2.19
AISPs must have in place suitable and effective mechanisms that prevent access to information other than from designated payment accounts and associated payment transactions, in accordance with the
customer's explicit consent.Added: December 2018OB-2.2.20
PISPs must provide the licensees maintaining
customer accounts with the same information requested from thecustomer when initiating the payment transaction directly, unless the collection of additional information for the purposes of the provision of the payment initiation service is agreed otherwise between PISP, payer, and the licensee maintainingcustomer accounts.Added: December 2018OB-2.3 OB-2.3 Payment Transactions
Consent to Initiate Payment Transactions
OB-2.3.1
A payment transaction is to be regarded as having been authorised by the payer for the purposes of this Module only if the payer has given its consent to:
(a) the execution of the payment transaction; or(b) the execution of a series of payment transactions of which that payment transaction forms part.Added: December 2018OB-2.3.2
For the purpose of Paragraph OB-2.3.1, such consent must be given in the form, and in accordance with the procedure, agreed between the licensee maintaining the
customer account, the payer and the PISP and may be given via the payee or a PISP.Added: December 2018OB-2.3.3
PISP must ensure that the payer can withdraw its consent to a payment transaction at any time before the point at which the payment order can no longer be revoked under the terms of the framework contract with the
customer .Added: December 2018OB-2.3.4
The
customer may withdraw its consent to the execution of a series of payment transactions at any time with the effect that any future payment transactions are not regarded as authorised for the purposes of this section.Added: December 2018Limits on Payment Transactions
OB-2.3.5
The PISP may agree on payment transaction limits based on its own discretion or on account of the following limitations:
(a) limits imposed by the CBB from time to time;(b) limits imposed by any of the licensees; and/or(c) limits imposed based oncustomer request.Added: December 2018OB-2.3.6
Subject to the framework contract, a PISP has the right to stop the use of a
payment instrument on reasonable ground relating to:(a) the security of thepayment instrument ; or(b) the suspected unauthorised or fraudulent use of thepayment instrument .Added: December 2018OB-2.3.7
PISPs must ensure that a
customer to whom apayment instrument has been issued must keep safe the personalised security credentials and must:(a) use it in accordance with the terms and conditions governing such use; and(b) notify the PISP in an agreed manner and without undue delay on becoming aware of the loss, theft, misappropriation or unauthorised use of thepayment instrument .Added: December 2018Fees and charges
OB-2.3.8
The AISPs and PISPs may charge fees and charges which reasonably corresponds to the AISP’s or PISP’s costs, as the case may be, which must be explicitly agreed in the framework contract.
Amended: July 2021
Added: December 2018OB-2.4 OB-2.4 Technology Related Requirements
OB-2.4.1
AISPs and PIPSs must adhere to the Operational Guidelines, Security Standards and Guidelines, Open Banking Application Program Interface (API) Specifications and Customer Journey Guidelines included in Bahrain Open Banking Framework “BOBF” (See CBB website) for the use cases defined in the BOBF. Where
licensees have arrangements to obtain access to customer account information or initiate payments for use cases not defined in BOBF, they must develop API Specifications, Customer Journeys and Operational Guidelines consistent with the Security Standards and Guidelines in BOBF.Amended: September 2024
Amended: July 2021
Added: December 2018OB-2.4.2
AISPs, PISPs must ensure that compliance with standards and guidelines specified in Paragraph OB-2.4.1 is subject to independent review and tests, including testing in a test environment, by an independent consultant upon implementation.
Amended: July 2021
Added: December 2018OB-2.4.3
AISPs and PISPs that offer services directly to end user customers must ensure that the technology solution provided to their
customers is easily accessible (e.g. website, IOS/Android/Microsoft Windows standalone application or other platform).Amended: January 2024
Added: July 2021