Four Steps to a Sustainable Future in the Open Banking Regime

How CDR and Open Banking is set to disrupt the banking sector

by Shan Yong and Amit Temurnikar November 2019


Data is growing and so is its importance to organizations. According to McKinsey,by 2020, about 1.7 megabytes a second of new information will be created for every human being on the planet”. The increasing volume of customer information can also be attributed to new technologies such as IoT and blockchain.

Millennials are aware of the value of data to organizations. They are not afraid of trading personal information in exchange for a greater value for goods and services. Without proper regulations in place, banks and third party apps use this data to generate insights and propositions without customer interference. All this is set to change with Consumer Data Rights (CDR) and open banking.

This article provides a future outlook on the ways in which banks will need to adapt to new challenges and opportunities to derive a sustainable competitive advantage in the open banking environment.

What is CDR and Open Banking?

What is CDR and Open Banking?

Consumer Data Rights (CDR) is being introduced in the Australian industry close on the heels of GDPR in Europe, with the Australian Competition and Consumer Commission as the regulator. Under this new law, customers can choose to give ‘consent’ to the banks to have their data shared with third party providers. This will give the customers more control and will also spur healthy competition between third party providers, fin-tech organizations, big 4 banks, smaller players and their associated subsidiaries.

Open banking is a secure way for customers to give third party providers access to their own data. The banks can now relay this information with accredited and trusted organizations. It will also allow customers access to their own data and products tailored to suit their financial needs.

Challenges and Opportunities of Open Banking

Challenges and Opportunities

The government has determined that CDR will immediately apply to the banking sector. For big 4 banks required to meet the CDR timeline of July 2020, there are many challenges. This shortage of time makes it critical for a bank to outline the steps required to thrive in the new open banking environment.

Open Banking Timeline

May 2017
May 2017

As part of the 2017 Federal Budget, the Government announced it would commission a review into Open Banking.

February 2018
February 2018

Scott Farrell releases the final report into Open Banking. Over 140 pages, the recommendations cover the regulatory framework, types of data, security and implementation.

May 2018
May 2018

The Government announced that it will agree to the recommendations in the Farrell review into Open Banking, including the consumer Data Right.

September 2018
September 2018

Framework released by ACCC for consultation. The backing sector will commence Comprehensive Credit Reporting, despite the legislation not yet having been passed in the Senate.

December 2018
December 2018

Draft legislation introduced into Parliament.

1 July 2019
July 2019

Four major banks to provide access to product data for credit and debit cards, deposit accounts and transaction accounts. Other banks are optional. Start of a beta testing of security, performance, and reliability of the system.

The four major banks included in the first implementation round of Open Banking include Commbank, ANZ, Westpac,and NAB

1 February 2020
February 2020

Four major banks provide access to consumer, account and transaction data for credit, and debit cards, deposit accounts, transaction accounts.  Product data for cards, deposits, personal loan, and other accounts.

1 July 2020
July 2020

The four major banks will provide access to consumer, account and transaction data for personal loan and other accounts. All other banks will provide access to product, account and transaction data for credit and debit cards, deposit accounts, and transaction accounts.

1 February 2021
February 2021

Other banks to provide access to product, account and transaction data for mortgage products.

1 July 2021
July 2021

All other banks to provide product, account and transaction data for personal loan and other accounts.

Products Included in Open Banking

Products Included in Open Banking

  • Savings Account
  • Call Accounts
  • Term Deposits
  • Current Accounts
  • Cheque Accounts
  • Debit Card Accounts
  • Transaction Accounts
  • Personal basic Accounts
  • GST and Tax Accounts
  • Cash Management Accounts
  • Farm Management Accounts
  • Pensioner Deeming Accounts
  • Mortgages
  • Business Finance
  • Personal Loans
  • Line of Credit
  • Overdrafts
  • Consumer leases
  • Credit and charge cards
  • Asset finance and leases
  • Mortgage offset account
  • Trust Accounts
  • Retirement and savings account
  • Foreign currency account

Steps to Succeed in an Open Banking Regime

Step 1. Know the current and future compliance plan

Organizations need to examine the current compliance strategy from key aspects of business such as maturity of the organization, business ecosystem, digital strategy, employee and customer awareness of CDR and IT and financial constraints. Once this is achieved, a re-compliance plan must be developed.

Step 2. Audit and log consent

Banks should ascertain the user consent at each stage of data sharing lifecycle. By logging and auditing consent at every stage of the content sharing lifecycle, banks can make efficient use of legal and available data for their new models and propositions.

Step 3. Adapt to business model changes

CDR poses a plethora of challenges to banks, but it also brings with it a number of opportunities. With CDR, banks can provide customers with higher than expected propositions to their target segments and further cement their position in the economy. The adjacent matrix highlights the steps a bank must take to make the most of the new business practices and their current core strengths.

Step 4. Monetize APIs

This step will be critical for the banks to stay relevant in the CDR regime. Banks will need to design an optimal strategy around consumption of their APIs for data sharing purposes. Key factors that need to be considered are:

  • API Strategy: New business models will require API management layers to enable exposure and consumption of services.
  • API Lifecycle: Once designed and developed, banks will need to form teams and deploy additional toolsets to ensure that the APIs stay relevant to the market demands.
  • Enterprise capability comprised of Enterprise APIs, Process APIs, and System APIs will ensure that the APIs are reusable, not monolithic, and easily maintained.
  • Adherence to banking standards (e.g. BIAN) will advocate greater compatibility acceptance.
  • Designing a flexible model that accommodates all scenarios from ‘required’ to ‘desired’ APIs from a compliance perspective. This will need a well established ecosystem for agile, risk free and cost effective implementation.
  • Australian banks can leverage the learnings in other markets further progressed with open banking ecosystems, combined with their business priorities.
Critical Success Factors

Critical Success Factors

Australian banks who are considering how to react to open banking should consider the following:

Second movers will share the advantage: Since the regulators are calling the shots, big banks and smaller banks who begin the process of adapting now will be equally placed to prosper as the open banking market grows and matures. This is because the smaller banks can build their ‘data-in’ strategy as the big banks join the compliance bandwagon to accomplish their ‘data-out’ requirements.

New partnerships and business models: Many banks already have established vendor partnerships to succeed in the open banking space. Since there is no market-ready offering, this is a bespoke, API-driven development and enables them with quick access to new capabilities and services.

Customer has the data right: Open banking gives the banks an opportunity to establish a strong bond with their customers across segments and keep track of their changing needs.

Speed of compliance and re-compliance: With tight industry timelines (see figure 1), regulators are pushing the Australian banks very hard to comply with CDR. However, once this is implemented, banks will need to keep an eye on further regulations that may be imposed based on the learnings in areas of fraud, security, and data breach.

Management of complaints: Once open banking is implemented, customers will have a lot of questions and concerns related to additional services. Banks will not only need to manage the external change and communication but also setup a robust in-branch and contact center experience to cater to issues, concerns, and complaints – to avoid any future compliance overheads.

There is no doubt that open banking will be the future of banking and financial services. This regime will also have the non-banking and technology providers offering payments and related financial services (E.g., Apple and Google already have payment solutions, Apple has already launched their credit card, fin-tech have prompted banks to change their business models). Open banking provides a further push to this and compels both the banks and fin-tech organizations to embrace this change.

Shan Yong

Shan Yong

Partner, Financial Services & Insurance Practice (APAC)

Shan has been with the firm since 2013 in various senior capacities. Based in Melbourne, he heads our financial services practice across Australia and New Zealand, leading some of our most innovative work in the space. His teams develop solutions and strategies to help senior business leaders drive change, transformation and new revenue opportunities for their organizations. Shan has 20+ of senior advisory experience across the financial services and telecommunications space, becoming an expert in enterprise architecture, strategy and governance. Prior to Infosys, Shan held senior roles at HOD Consulting Fiserv. He is a regular speaker at client events and a key contributor to our firm’s thought leadership channels.

Amit Temurnikar

Amit Temurnikar

Principal, Infosys Consulting

Amit is part of our CIO Advisory practice in Australia and focuses on IT strategy and architecture, digital CX and agile transformations within banking and financial services. With over 17 years in the IT and consulting space, Amit has leveraged the breadth of his knowledge to shape complex multi-functional engagements and publish thought-leadership content. He has managed various top client accounts in the region, leading their business strategy and facilitating the implementation of unique IT solutions. Amit has an MBA and a bachelor’s degree in computer science. He is also certified in TOGAF and SAFe.

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