Programme phases

    Three phases, each a stable state with criteria for moving to the next. Mirrors the UK Open Banking sequence and is structured to give regulators a predictable evidence cadence.

    flowchart LR P1["`Phase 1 — Sandbox *operational 2025–26*`"]:::success P2["`Phase 2 — Live trust framework *2026–27 (planned)*`"]:::warning P3["`Phase 3 — National rollout *2027+ (planned)*`"]:::warning P1 --> P2 --> P3
    Sandbox is the current state. Phase 2 begins when the Sandbox exit criteria are met.

    Phase 1 — Sandbox

    Status: operational today. CLC + OPDA + Raidiam, funded by the Regulators' Pioneer Fund.

    Goal: build and stress-test the technical, regulatory and governance foundations of the trust framework in a controlled environment with real participants.

    WorkstreamWhat's being delivered
    TechnicalPDTF schemas v3.4+, OpenAPI v1.2, validation tooling, conformance test suite
    GovernanceTrust framework spec, accreditation criteria, consent & liability model
    OperationalRaidiam-run Sandbox infrastructure, participant onboarding process, audit regime
    RegulatoryGap analysis fed back to MHCLG, DSIT and FCA

    Exit criteria (proposed):

    • ≥ 10 Sandbox participants completing the full transaction flow
    • Conformance test suite passing for all participating data sources
    • Regulator buy-in (FCA + ICO) on the consent/liability model
    • MHCLG-published material-information successor guidance incorporated into the nts.json overlay
    • Independent operational-readiness review completed

    Phase 2 — Live trust framework

    Status: planned 2026–27.

    Goal: open the production trust framework to accredited participants. Move from "controlled cohort" to "anyone meeting the criteria can join".

    • Productionised trust-framework infrastructure (not a sandbox copy)
    • Live conformance scheme — independent body issues certifications
    • Published accreditation criteria with a public participant register
    • Regulatory wrapper — likely FCA authorisation regime per the Smart Data Scheme model
    • Public dispute / incident-response process

    Exit criteria (proposed):

    • ≥ 50 certified participants across all six bounded contexts
    • Quarterly audit cycle running with public reports
    • End-to-end transactions running on the live framework at scale
    • Consumer-facing brand awareness comparable to Open Banking at the 2018–2019 mark

    Phase 3 — National rollout

    Status: planned 2027+.

    Goal: industry-wide default. PDTF becomes the standard exchange layer for property data; non-conformant alternatives become rare and uncompetitive.

    • Mandatory conformance for regulated activities (estate-agency Material Information, conveyancing, mortgage lending)
    • Cross-jurisdiction expansion — Scotland, Northern Ireland aligned
    • International peer-recognition (e.g. with similar property data initiatives in Australia or the Netherlands)
    • OPDA evolves to a steady-state standards body, more like the Open Banking Implementation Entity in maturity terms

    Open Banking precedent

    The phasing intentionally echoes the UK Open Banking timeline:

    • 2016–2017: CMA Order, Open Banking Implementation Entity stood up — equivalent to today (DPMSG + OPDA forming)
    • 2018: CMA9 banks live with read APIs — equivalent to Phase 2
    • 2019–2021: Variable Recurring Payments, broader fintech adoption — equivalent to Phase 3

    Raidiam's involvement is significant precisely because they ran the equivalent Open Banking infrastructure in Brazil and worked on the UK Open Banking project — so this is not a from-scratch design.

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