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.
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.
| Workstream | What's being delivered |
|---|---|
| Technical | PDTF schemas v3.4+, OpenAPI v1.2, validation tooling, conformance test suite |
| Governance | Trust framework spec, accreditation criteria, consent & liability model |
| Operational | Raidiam-run Sandbox infrastructure, participant onboarding process, audit regime |
| Regulatory | Gap 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.jsonoverlay - 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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