By Jarrid Ohanessian, GM illion Open Data Solutions

The ACCC has recently published the latest set of feedback on further changes to the Consumer Data Right (CDR) rules which are part of Australia’s emerging open banking system. These changes are aimed at making CDR data more widely available, with lower barriers to entry.

As Australia’s oldest and most established FinTech, illion supports these changes, and we have long advocated for a system that makes it easy for individuals to securely share their data to get the best possible outcomes in the most efficient manner.

We have demonstrated our commitment to reform in this space by investing significantly to achieve Accredited Data Recipient status for our illion Open Data Solutions and Credit Simple businesses.

Our views on the CDR framework are well established — it will provide substantial benefit to financial services consumers, transforming the way they interact with the banking system by providing the ability and tools to safely share data with different lenders, other financial institutions and FinTech companies.
We welcome the consultative position that the ACCC has adopted with the industry on these matters, and were encouraged by the introduction of the Principle Provider model in the most recent rules amendment.

But while illion appreciates the ACCC’s efforts to advance open banking in Australia, we feel the latest proposal still lacks the level of access that is needed to reduce the barriers to entry and enable wide use of Open Banking through the CDR.

illion’s submission

In our submission to the ACCC this month we are strongly encouraging a much less prescriptive approach is taken that allows a consumer, with consent, to enable their data to be used by third parties, which we understand to be the objective of the CDR.

In doing so, consumers will be able to access the most appropriate and economical financial products to suit individual needs. Likewise, granting access to consumer data will ensure providers will be able to offer innovative products at more competitive rates.

illion believes that intermediaries such as credit reporting bodies, will be crucial in enabling a secure and practical implementation of the CDR in Australia, beginning with open banking and followed by the energy sector.

Many of our clients who are growing fintechs, and mortgage brokers had told us they were not considering using open banking and the CDR because it is an expensive, time consuming and overly complex system.

With an estimated cost of $250k to gain accreditation, and ongoing costs to maintain secure data standards and keep up with regulatory changes, the barrier to entry is too high for most Australian businesses that would see benefit from using the CDR.

The proposed rules changes allow for brokers and other Trusted Advisors to access CDR data without accreditation. This is a very positive step forward, but illion’s position is that it should be expanded even more widely. Failure to do so runs the risk that consumers will not see the benefits of controlling their own data, because only few firms can take advantage.


illion believes that in order to grow usage of open banking, barriers to entry need to be reduced. Open banking should be able to be used by lenders, growing FinTechs, accountancy firms and brokers. CDR should enable consumer benefits through firms being innovative in the market. With the current legislation being so restrictive, we are stifling that innovation.

We will continue to speak out for the industry on these important matters, and look forward to keeping you posted on how these changes progress, and how we can support you and your customers.

About illion

In many ways we are Australia’s oldest FinTech. We have been in the data market in Australia for over 130 years and we have deep industry expertise. We have set up our own FinTech, Credit Simple, now with over one million members in Australia. We also run illion Open Data Solutions (formerly Proviso), the leading aggregator of banking data in Australia.

illion’s digital infrastructure is relied upon by over 15,000 corporate and government clients, and over 1.3 million consumers. It is vital that regulatory reforms in our sector satisfy consumer demands and continue to foster an environment that enables agile data solutions.