Payments Canada outlines recommendations for Canada's consumer-driven banking framework

Response to Department of Finance consultation highlights key considerations for transition to ‘read’ access.

In its response to the Department of Finance consultation on the proposed Consumer-Driven Banking Regulations, Payments Canada welcomes the establishment of a regulatory foundation for financial data sharing. The response highlights that a sound regulatory framework for the initial "read" access phase is essential to pave the way for what comes next. 

As the framework continues to progress into a "write" access phase, Payments Canada looks forward to supporting the Department of Finance, the Bank of Canada and the designated Technical Standards Body to help advance policy development at the intersection of consumer-driven access and payment initiation.

Read the full response below.

Payments Canada’s views on proposed Consumer-Driven Banking Regulations

Please note that this submission reflects the positions and perspectives of Payments Canada in alignment with our mandate, and does not necessarily represent the individual views of our broader membership or stakeholder base.  

Payments Canada welcomes the opportunity to comment on the proposed Consumer-Driven Banking Regulations. Advancement of a sound regulatory framework for the initial phase of consumer-driven banking is a necessary step towards paving the way for what comes next. The federal government’s Budget 2025 included a commitment to extend the framework to write-access including payment initiation by mid-2027, and signalled an important role for Payments Canada and the new Real-Time Rail (RTR). Payments Canada recognizes that real-time payments, along with broad access and the “write” phase of consumer-driven banking can enable greater innovation for Canadians. This evolution must prioritize a trusted, sound and secure framework. Payments Canada is well positioned to help the government succeed in developing effective policy on write-access by providing essential expertise in areas such as payment infrastructure, interoperability and payment initiation considerations.

Key considerations

Conditions for success

Successful implementation of “read” access will provide a necessary foundation for moving towards the “write” phase. Ensuring this foundation is proven, secure and effective will help pave the way for a successful second phase of consumer-driven banking. Any transition towards payment initiation must be supported by a framework that addresses such things as security, fraud controls, accountability, liability and clear and consistent mechanisms for recourse and dispute resolution.  

As part of this safe and sound transition:

• Screen scraping should be prohibited following a clearly defined transition period once API-based data sharing capabilities are available, tested and operational;
• Interoperability with Payments Canada’s payment infrastructure should be a key design consideration for any future write-access framework to support payment initiation; and
• Operational readiness across the ecosystem should be supported.

Ecosystem collaboration and Payments Canada’s role 

Achieving the full benefits of consumer-driven banking and real-time payments will depend on deliberate coordination across governments, regulators, system operators, financial institutions and accredited participants. Clear governance, aligned implementation timelines and leadership will be essential to ensure these complementary initiatives evolve together and deliver secure, innovative and widely adopted payment experiences for Canadians. Ongoing engagement will be important to ensure the framework is designed in a way that supports secure data sharing, promotes innovation and competition, and maintains the safety, soundness and integrity of Canada’s financial ecosystem. 

Payments Canada is well positioned to support the government’s work on the next phase of consumer-driven banking, providing expertise regarding payment systems, standards development and interoperability. In pursuing its legislative mandate, Payments Canada has a duty to promote the efficiency, safety and soundness of its clearing and settlement systems and take into account the interests of users.¹ Our knowledge and expertise in these areas can help to inform key policy decisions around such things as security, fraud controls, accountability, liability, recourse, operational risks, testing and industry-wide preparedness.

As implementation of the read-access phase progresses and efforts advance on the policy framework for write-access, Payments Canada will seek to:

• Work with the Department of Finance, the Bank of Canada and industry participants to support the safe, secure and effective transition towards write-access; and
• Foster a close partnership with the entity appointed as the Technical Standards Body to ensure continued seamless interoperability between the consumer-driven banking technical standards and Payments Canada systems.

Conclusion

As Canada approaches the launch of the RTR and continues to advance consumer-driven banking, it is building the infrastructure for a more empowered Canada. This foundation will enable Canadians to have greater autonomy over their financial data and the ability to execute on these decisions in real time through the RTR. The proposed regulations are an important first step toward enabling consumer-driven banking in Canada. A successful framework roll-out depends on a phased transition that seeks to address risk while enabling innovation. 

Payments Canada looks forward to supporting the Department of Finance when it shifts its focus from read to write-access. Payments Canada is equipped to bridge the consumer-driven banking framework with the broader payment ecosystem, helping advance policy development at the vital intersection of consumer access and payment initiation.

¹Users refers to Canadians, including individuals, businesses, and other end users of payment services, that are distinct from Payments Canada members and system participants.