OFNC calls for a clear roadmap in submission supporting Consumer-Driven Banking regulations

The Open Finance Network of Canada (OFNC) submitted comments to the Department of Finance Canada and the Bank of Canada last week, ahead of the August 26 deadline, on the proposed Consumer-Driven Banking Act regulations.

The submission welcomes the framework’s overall direction and sets out nine recommendations intended to support its implementation for the benefit of Canadian consumers and small and medium-sized enterprises (SMEs).

Its leading recommendation includes OFNC suggesting that a clear, integrated implementation roadmap be published, setting out target dates and responsibilities for each deliverable, critical policy and technical dependencies, testing, certification, minimum notice periods, readiness criteria, and contingency arrangements, reported publicly at regular intervals.

OFNC also proposes that designation of the technical standards body and the common technical standard take place before or alongside final publication of the regulations, with balanced governance across financial institutions, fintechs, technology providers and consumer groups.

On scope, OFNC recommends limiting Phase 1 to active account data available through online banking, excluding static, consumer-specific legal documents, while publishing generic product terms and pricing early through a separate, lighter mechanism, consistent with the approach taken in the UK and Australia. It further suggests a clear Phase 2 roadmap setting out the sequencing of write access, wealth and investment data, and related fraud, liability and authentication requirements.

To ease the transition for smaller organizations, OFNC recommends scaling compliance obligations by risk and market impact rather than by category of entity, phased in, starting with the largest institutions, echoing the approach taken in the UK and Australia. On the screen-scraping prohibition, OFNC supports tying enforcement to a transparent, quantitative readiness assessment covering API coverage, reliability, consumer adoption and complaint trends, rather than a fixed date.

Other recommendations touch on operational guidance for liability in multi-party incidents and downstream data use, alignment of consent and re-authentication rules across federal and provincial privacy regimes, and clarity on data-sourcing responsibilities for partner-originated and investment products.

On access, OFNC notes that initial scope appears focused on consumers and sole proprietorships, though SMEs more broadly are expected to be key beneficiaries. Multi-owner business accounts raise consent questions not present for individual consumers, and the organization has asked that a clear timeline for extending access to full SMEs be published alongside clear rules for multi-signatory and multi-user consent, developed in consultation with SME and industry stakeholders.

Finally, OFNC has proposed a public dashboard drawing on metrics already used in the UK and Australia, such as API availability and response times, supplemented with Canada-specific indicators including complaint resolution times and small-business adoption and benefit, with clear baselines for regular reporting.

Michelle Beyo, president of OFNC, said: “OFNC welcomes the proposed Consumer-Driven Banking Regulations and supports the overall direction: oversight by the Bank of Canada, common rules, proportionate accreditation and a measured approach to prohibiting screen scraping.”

Beyo added: “OFNC commends the Department of Finance and Bank of Canada for advancing this framework to the regulatory stage. These recommendations are intended to improve implementation certainty without compromising regulatory flexibility, consumer protection or security.”

Catch Michelle Beyo, president, OFNC on the Smart Data Stage at Open Banking Expo UK & Europe 2026 on 13 to 14 October at the Business Design Centre in London. Click here to see the full agenda and register to attend.