FDATA, the trade association representing more than 30 financial technology companies and consumer-permissioned data access platforms, has submitted formal comments to the Department of Finance Canada raising concerns that proposed accreditation rules under the FDATA Consumer-Driven Banking Act framework could shut out the very fintechs the legislation was designed to help.
The submission, published on 27 August 2026, broadly praised the Department’s goal of building a competitive, secure, and consumer-focused open finance ecosystem. But it argued that several implementation choices, particularly around accreditation costs and regulatory complexity, risk undermining that ambition before the framework has had a chance to take hold.
What the Consumer-Driven Banking Act actually requires of applicants
The Consumer-Driven Banking Act (CDBA) received royal assent in March 2026, according to the Canada Gazette. Proposed regulations released for comment set out four accreditation pathways intended to reduce duplication for entities already subject to regulatory oversight. FDATA’s letter acknowledged that logic, but argued the pathways could still impose disproportionate burdens on smaller firms.
On the cost question, the picture is concrete. According to Blakes, applicants for accreditation are required to pay an accreditation fee of C$2,500, subject to annual indexation and rounding. FDATA’s concern is not with that headline figure alone, but with what it represents within a broader cost structure that could make participation prohibitive for smaller entrants operating on thin margins.
‘High accreditation costs could exclude smaller fintechs and undermine the CDBA’s goal of broad participation and competition,’ FDATA’s 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.’
The Sponsored Fintech Model and what FDATA is asking for
To address the participation problem, FDATA proposed what it calls a Sponsored Fintech Model: an additional, optional pathway for participation within the consumer-driven banking framework that would preserve robust consumer protections without forcing smaller firms through the full accreditation machinery. The association also made recommendations aimed at simplifying the accreditation process more broadly and reducing regulatory complexity.
FDATA further asked the Department to provide greater clarity on a set of key terms that currently carry ambiguity: ‘place of business in Canada’, ‘insurance or comparable guarantees’, ‘derived data’, and ‘significant change’. The letter explained that clearer definitions would reduce the risk of inconsistent interpretation across applicants and regulators, making the accreditation process more predictable for everyone operating within the framework.
The submission also addressed what firms can do with the data once they have it. FDATA said it supports the scope and use of data included in the CDBA framework, but called for greater clarity on how consumer-permissioned data may be used internally for product development, fraud prevention, and risk management. This is not a trivial question: ambiguity here could discourage legitimate uses that the framework’s drafters almost certainly intended to permit.
Boms framed the overall package of recommendations as consistent with the legislation’s stated goals rather than in tension with them. ‘These recommendations will strengthen the implementation of CDBA while preserving its core objectives of promoting competition, innovation, consumer choice, and financial stability,’ he said. ‘These measures collectively encourage broad market participation while upholding high standards of security and consumer protection that Canadians rightly expect.’
The Department’s consultation period on the proposed CDBA regulations remains open, and FDATA’s submission is one contribution to that process. Whether the Department takes up the Sponsored Fintech Model or addresses the terminology concerns the letter raises will become clearer once the final regulatory text is published.
