NatWest and National Australia Bank’s (NAB) white paper explores the common threads that bind both Australia’s Consumer Data Right (CDR) and the UK’s Open Banking regime. Despite similarities in the policies, the two countries have diverged in their journeys to implementing these frameworks, notably in relation to their respective scope in terms of ‘breadth versus depth’.

Both the UK and Australia have enacted regimes which mandate the sharing by banks of customer data with third parties, with customer consent. Both regimes share similar policy underpinnings that aim to increase competition, innovation and empower consumers with control over their data.

However, a recent whitepaper co-authored by NatWest and Australia’s NAB finds the two countries have also diverged in their journeys to implementing these frameworks. Most notably in relation to their respective scope in terms of ‘breadth versus depth.’ The UK system was designed from the outset with depth of functionality in mind, whereas Australia has leaned towards breadth of data sharing across the economy.

Whilst Australia’s Consumer Data Right (‘CDR’) regime was modelled on the United Kingdom’s ground-breaking open banking framework, it departed from its predecessor, which confined itself to the sharing of banking information and to payment services, finds the paper.

“We have lessons to learn here in the UK from Australia’s approach to the CDR – especially in terms of the breadth of data access being implemented there. It’s important the industry acts on this insight from Australia as we transition from open banking to open finance and smart data in the UK,” says Claire Melling, Head of Bank of APIs, NatWest.

Unique

Australia’s regime is now globally unique in its intended breadth of coverage as a whole of economy data portability framework. In this regard the CDR has been prescient in its ambition, states the whitepaper. Equally, the depth of the functionality of the UK open banking regime (beyond mere read access), is often lauded as having ‘turbocharged’ the regime in terms of consumer uptake and the sophistication of product offerings.

The UK and the Australian regimes are now at a critical juncture of their respective development, with the UK looking beyond banking and finance to open data and Australia shifting focus to ‘system functionality and growth.’

Questions

Three to four years on, is open banking in the UK and the CDR in Australia heading in the right direction? And are they moving quickly enough to be impactful in their respective economies?

The whitepaper contends both countries are heading in the right direction, however, reform is needed to ensure these regimes keep pace with technological change and achieve their potential to enable greater competition, innovation and ultimately deliver benefits to consumers in both nations.

Both jurisdictions should keep in mind global interoperability to ensure they remain at the forefront of technology-led trade and look beyond a sectoral approach and towards “open data.” As Australia extends the CDR to action initiation and across sectors, Australia should learn from the UK’s successes in building on existing legal frameworks and infrastructure, rather than duplicating regimes.

The report authors also argue that Australia should look to mirror aspects of the effective collaboration between industry and regulators in implementing the open banking regime, including considering a role for a purpose-built implementation entity that heeds the experience of the UK’s Open Banking Implementation Entity (OBIE).

Meanwhile, the UK should continue to take a forward leaning approach, as Australia has done, in extending open banking to be an economy wide data sharing regime. The report concludes both countries should also embed a role for digital identity, without which the regime will not be able to scale and deliver the promised benefits to consumers and the economy.

“Consumers are now looking for more integration and connection between the main experiences they have every day, and that means evolving from ‘open banking’ to ‘open data’,” said one of the report’s authors, NAB Executive Digital & Data Governance, Brad Carr.

“There are several insights and lessons we can glean from Australia and the UK’s journeys in relation to open banking and the CDR. It has been great to partner with our friends at NatWest on this report, as the UK was an early adopter of open banking and many other nations, including Australia, looked to the UK’s experience in developing their own regimes.”