Another Fork in the Road for the Future of Open Banking
Nov 3, 2025 | 4 min read
Nov 7, 2025|0 min read
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Earlier this week, the Canadian government injected significant momentum into its Consumer-Driven Banking Act — and Open Banking journey — with the release of Budget 2025. This isn't just another incremental step; it provides the much-needed regulatory clarity and time frames that the industry has been waiting for, setting the stage for the practical implementation of a national data-sharing framework.
The most pivotal announcement is the shift in regulatory oversight. The responsibility for the administration, oversight, and enforcement of the Consumer-Driven Banking Act (CDBA) framework is being transferred from the Financial Consumer Agency of Canada (FCAC) to the Bank of Canada (Canada's Central Bank).
This move is strategically designed to create a more streamlined and consolidated regulatory environment. The Bank of Canada already supervises Payment Service Providers (PSPs) under the Retail Payment Activities Act (RPAA). Placing the CDBA under the central bank's control reinforces the framework's focus on systemic stability, security, and the integration of Open Banking with new payment infrastructure like the Real-Time Rail (RTR).
While the government has not announced a single, final "launch date" for the entire system, Budget 2025 sets a major concrete goal: legislating the advanced functionality known as "write access" by mid-2027.
"Write access" moves beyond simply viewing data ("read access") and allows a consumer to direct an action on their behalf through an accredited third-party app. This high-value functionality enables core use cases such as:
The mid-2027 deadline is set to take place after the launch of the Real-Time Rail (RTR) payment system. This is a timeline that all industry participants — from established financial institutions to fintechs — must now use to align their strategic and technical development roadmaps.
In a signal of a broader policy vision, the government confirmed its intent to introduce a data-mobility right within the Personal Information Protection and Electronic Documents Act (PIPEDA).
This move indicates that the policy is much larger than just the financial sector. It suggests a future where consumers have the right to securely move their data across various sectors — not just banking, but potentially telecom, utilities, and other consumer services.
For innovators, this broader vision presents a massive opportunity to eventually open up new data sources, enabling the creation of more holistic financial and service products.
The coming years will be crucial as financial institutions, fintechs, and other stakeholders work to build the infrastructure and services that will empower Canadian consumers with greater control over their financial data and pave the way for a more integrated and efficient digital economy.
For more than a decade, MX has been a leader in Open Banking and consumer-permissioned data sharing. We strongly believe that consumers should own their financial data, with a great need for regulations supporting that ownership. Financial institutions have the responsibility to create better financial opportunities for consumers that permit data sharing.
MX’s Data Access solution combines an API platform that meets FDX standards with built-in analytics to create actionable intelligence — for consumers and their institutions.
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