Cogo: Green FinTech Challenge case study

Cogo helps users understand and offset their carbon footprint via an app. Find out how we supported this innovation through the Green FinTech Challenge.

Cogo is an app that connects users with businesses that align with their social and environmental values.

The app, which is free to use, allows users to understand their carbon footprint by assigning a carbon emission factor every time they spend. The app then shows users how to improve and compensate for their climate impact, with a selection of credible, global carbon offsetting projects.

Our support

Cogo was one of 9 firms accepted into the pilot Green FinTech Challenge 2018. As part of the challenge, the team asked whether the firm’s activities would meet the definition of an account information service provider (AISP) under the Payment Services Regulations 2017 (PSRs).

We provided Cogo with one of our regulatory tools, an informal steer. This set out the definition of an account information service (AIS) as described in our Handbook.

Our Handbook (PERG 15 Question 25A) also provides more information on additional circumstances when AIS are being provided. The definition of AISPs includes: 

  • businesses that provide users with an online ‘dashboard’ where they can view information from various payment accounts in a single place
  • businesses that use payment account data to provide users with personalised comparison services supported by presentation of account information
  • businesses that provide information from the user’s various payment accounts to both the user and another party (such as a lender or a financial advisor) on a user’s instruction

We worked closely with Cogo to understand their business model, user journey and what regulated activities were being carried out. Our view, set out in the informal steer, was that the firm would likely be providing AIS under the PSRs.

Next steps

Following our support, in October 2019 the firm registered with to provide payments services. A month later, the firm launched its new Open Banking integrated Living Wage wallet, in partnership with the Living Wage Foundation.

Cogo has since entered partnerships with several UK banks, including developing a carbon footprint tracking feature for a mobile app and personalised carbon footprints for customers of one firm, based on their spending data.