FDATA submits comments to Canada’s Finance Department on Consumer-Driven Banking Act

Source: FDATA

The Financial Data and Technology Association (FDATA), a trade association representing more than 30 financial technology companies and consumer-permissioned data access platforms, submitted comments to the Department of Finance Canada (The Department) regarding the Consumer-Driven Banking Act (CDBA) regulations. While FDATA praised the Department’s goal to create a competitive, secure, and consumer-focused Open Finance ecosystem, it raised concerns about accreditation and other key implementation issues.

The letter argued that while the four proposed accreditation pathways would reduce duplication for already-regulated entities, they could inadvertently create disproportionate barriers for smaller firms and fintechs that Canada’s consumer-driven banking framework is intended to support.

“High accreditation costs could exclude smaller fintechs and undermine the CDBA’s goal of broad participation and competition,” FDATA executive director Steve Boms said.

“This framework will only achieve its full potential if fintechs and institutions of all sizes can participate while maintaining strong and consistent consumer protections.”

To address these concerns, FDATA proposed a Sponsored Fintech Model that would establish an additional, optional pathway for participation within Canada’s CDB framework and preserve robust consumer protections.

FDATA made other recommendations aimed at simplifying the accreditation process and reducing regulatory complexity, including urging the Department to:

• Publish rules and technical standards well before implementation.
• Preserve the streamlined accreditation process for already regulated Payment Service Providers (PSPs).
• Recognize fintechs that have already complied with similar Open Banking rules abroad.
• Provide more clarity around national security reviews.

FDATA further requested that the Department provide greater clarity on key terms, including “place of business in Canada”, “insurance or comparable guarantees”, “derived data”, and “significant change”. Clearer definitions would reduce the risk of inconsistent interpretation, thereby promoting a more predictable accreditation and operational framework, the letter explained.

FDATA concluded the letter by supporting the scope and use of data included in the CDB framework, while calling for greater clarity on how consumer-permissioned data may be used internally for product development, fraud prevention, and risk management.

“These recommendations will strengthen the implementation of CDBA while preserving its core objectives of promoting competition, innovation, consumer choice, and financial stability,” Boms said.

“These measures collectively encourage broad market participation while upholding high standards of security and consumer protection that Canadians rightly expect.”

FDATA is an Industry Partner of Open Banking Expo UK & Europe 2026, which takes place on 13-14 October at the Business Design Centre in London. Click here to find out more.

Listen to FDATA’s Steve Boms on the Open Banking Expo Unplugged podcast: ‘How is Open Banking playing out in the US and Canada?’

Further reading: FDATA calls for a principles-led framework for the next generation of Open Finance