The Blake, Cassels & Graydon LLP analysis of Canada’s open finance trajectory provides useful context: the Consumer-Driven Banking Act received Royal Assent on 26 March 2026, with proposed regulations released for comment on 27 June 2026. The Open Finance Network of Canada (OFNC) has now responded, filing a detailed submission ahead of the 26 August deadline that centres its OFNC implementation roadmap recommendations on nine specific points intended to shape how those regulations take effect.
At its core, consumer-driven banking permits individuals and businesses to securely share their financial information with authorised third-party providers through application programming interfaces (APIs), as DLA Piper sets out in its own commentary on the draft regulations. The OFNC submission, directed to the Department of Finance Canada and the Bank of Canada, broadly welcomes that direction while identifying implementation gaps it says need addressing before the framework can deliver for Canadian consumers and small and medium-sized enterprises (SMEs).
A roadmap with dates, owners and contingency plans
The lead OFNC implementation roadmap recommendation is, by the organisation’s own framing, the most fundamental: publish a clear, integrated implementation roadmap that sets out target dates and responsibilities for each deliverable. The submission specifies that this roadmap should cover critical policy and technical dependencies, testing, certification, minimum notice periods, readiness criteria and contingency arrangements, and that progress should be reported publicly at regular intervals.
Alongside that, OFNC proposes that designation of the technical standards body and the common technical standard take place before or alongside final publication of the regulations. Governance of that standards body, the submission says, should be balanced across financial institutions, fintechs, technology providers and consumer groups.
Phased scope, proportionate obligations and a metrics dashboard
On scope, the organisation recommends limiting Phase 1 to active account data available through online banking, excluding static, consumer-specific legal documents. Generic product terms and pricing should, in OFNC’s view, be published early through a separate, lighter mechanism, consistent with the approach taken in the UK and Australia. A clear Phase 2 roadmap, it adds, should set out the sequencing of write access, wealth and investment data, and related fraud, liability and authentication requirements.
To ease the transition for smaller organisations, the submission recommends scaling compliance obligations by risk and market impact rather than by category of entity, phased in starting with the largest institutions. That approach echoes, explicitly, what was done in the UK and Australia. On screen scraping, OFNC supports tying any prohibition to a transparent, quantitative readiness assessment covering API coverage, reliability, consumer adoption and complaint trends, rather than a fixed date.
Other recommendations address 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.
The question of SME access gets its own treatment. The submission notes that the initial scope appears focused on consumers and sole proprietorships, though SMEs more broadly are expected to be key beneficiaries of the framework. Multi-owner business accounts, it observes, raise consent questions not present for individual consumers. OFNC 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, the organisation proposes a public dashboard drawing on metrics already in use 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. The submission calls for clear baselines for regular reporting.
Michelle Beyo, president of OFNC, said the submission was intended to improve implementation certainty ‘without compromising regulatory flexibility, consumer protection or security.’ She added that OFNC ‘commends the Department of Finance and Bank of Canada for advancing this framework to the regulatory stage.’
Beyo also welcomed oversight by the Bank of Canada, common rules, proportionate accreditation and a measured approach to prohibiting screen scraping as elements the organisation supports in the proposed framework.
Beyo is scheduled to appear on the Smart Data Stage at Open Banking Expo UK & Europe 2026, taking place 13 to 14 October at the Business Design Centre in London.
