Consumer Data Right

The first iteration of the CDR in Australia – a limited pilot involving the four majors – went live on 1 July 2019.


The Consumer Data Right (CDR) legislation was passed by Parliament on 1 August 2019.

Given the inevitability of the CDR, the question ADI and FinTech Boards should be asking is not whether to adopt the CDR, but how to make the most of it. In this context, Gen Advisory has observed several compelling CDR use cases which we believe would benefit any ADI which adopts them.

At a Glance

Critical Dates

Open Banking Grid-01.png

Our Analysis

What Is It?
The Future
Key Issues

Under Open Banking, customers will be given the right to instruct their existing bank to share their data with other banks and accredited FinTechs.

Open Banking is aimed at giving customers more choice, control convenience, and confidence

After banking, the CDR will be extended to other sectors such as telecommunications and energy.

In Gen Advisory’s view, Open Banking will significantly level the competitive playing field between the majors, non-majors, and alternative service providers.

API development.


Value proposition & strategy formulation.

Use cases.

Cyber-security and resilience. 

Privacy policies.

Data analytics.

Risk-based pricing.



Existing ADIs and neo-banks could expand and enhance their native offerings. 

Increase appeal to existing and prospective customers. 

New value propositions.

New revenue streams.

Enables competitors to tap into an ADI's and FinTech's data and then offer competing products/services.

Note however that FinTechs are currently already doing this through a process known as screenscraping.

What ADIs and FinTechs need

to do to be ready for the CDR

How we can help ADIs and

FinTechs implement the CDR

  • At a minimum, ADIs and FinTechs need to develop a sufficiently robust application programming interface (API) in order to meet their data-sharing obligations under Open Banking. 

  • More importantly, ADI and FinTech Boards need to assess broader factors such as customer-retention strategies; product and service offerings; cyber-security and resilience; privacy policies; and data analytics, among others.

  • Provide strategic advice to ADI and FinTech Boards on Open Banking requirements, use cases, and opportunities vs threats. 

  • Deliver bespoke research on a specific Open Banking-related area of interest.

  • Deliver bespoke training on Open Banking.

  • Manage and execute, on an ADI or FinTech's behalf, an end-to-end project on Open Banking.

  • Conduct due diligence on prospective Open Banking solutions providers.