After nearly a decade of consultation, Canada is finally building. Consumer-Driven Banking is live in legislation, the Bank of Canada has its mandate, and the 2026/2027 milestones are real. The question is no longer whether Canada will have an open finance framework – it’s whether the execution will match the ambition. 

At Open Banking Expo Canada, Invela’s Jim Wadsworth chaired the debate on Consumer-Driven Banking with the full ecosystem perspective brought to life by Eyal Sivan, GM NAM, Ozone;  Adriana Vega, CEO, Fintechs Canada; Abraham Tachjian, Chief Regulatory Affairs Officer, Brim Financial and Heather Davis, Senior Director Innovation, CIBC. 

Here are eight things that stood out. 

1. Canada built a consumer regime, not a punishment regime 

Most jurisdictions came to open banking as a disciplinary tool – a regulatory stick to beat incumbents who’d had it too good for too long. Canada chose differently. From the very first 2017 Department of Finance consultations, the design intent was consumer welfare and data rights, not market correction. 

That choice shows up everywhere: in reciprocal data rights, in the push for genuine network effects rather than a gated club, in the insistence on privacy anchored to existing frameworks rather than a parallel regime. It’s a strategic bet that empowered consumers and strong rails will do more for competition than regulatory retribution ever could. 

2. Accreditation is the new centre of gravity 

Everyone agrees on the destination. The hard part is the machinery that gets there without destroying trust. Two themes dominated: accreditation that actually scales, and third-party risk management (TPRM) as a first-order problem. 

If you want network effects, you can’t build a system where only a handful of players can realistically participate. That means clear, enforceable baseline standards; tiered obligations that reflect actual risk profiles (a small non-deposit lender is not a global bank); and a process predictable enough that fintechs and merchants can confidently invest. 

“When you’re creating an ecosystem based on an open standard, there’s a whole bunch of new players coming along. How do you know you can trust them?” 

TPRM can’t be an afterthought. The ecosystem needs clear ways to vet participants, shared expectations on liquidity, operational resilience, security, and redress – and an honest decision about how much of that is regulator-driven versus market-driven. 

3. Stop underestimating consumers (but do explain consent) 

Millions of Canadians have been using screen-scraping-based services for years. Data sharing isn’t a foreign concept. The panel’s nuanced take: don’t build a hand-holding campaign about open banking as a brand. Consumers don’t care about the label. They want better mortgage rates, smarter cashflow tools, fairer credit decisions. 

But they do need to understand what they’re consenting to, how their data will be used, and – crucially – how to revoke that consent. In the analogy used on stage: consumers don’t need to know how electricity works. They just need to know they can unplug the lamp, and what happens if it sets the curtains on fire. 

4. Trust is invisible until it fails 

If there’s a failure in the ecosystem – a bad actor, a data breach, a payment gone wrong – who is on the hook? Where does the consumer go for redress? Is the experience clear, predictable, and fair? Or is it a Kafkaesque tour of finger-pointing across banks, fintechs, and regulators? 

Clarity on liability, complaints handling, dispute management, and regulatory escalation paths is not back-office plumbing. It’s the front line of trust, and a competitive differentiator for the whole ecosystem. One bad episode doesn’t just destroy confidence in a single provider – it damages appetite for the next innovation too. 

5. Real-time rails give Canada an asymmetric advantage 

Unlike markets where instant payments and open banking arrived a decade apart, Canada is bringing Consumer-Driven Banking, the Real Time Rail, and stablecoin infrastructure on a broadly similar timetable. That convergence matters: real-time rails without strong access frameworks risk becoming real-time fraud rails. Open data without modern payment rails risks being clever analytics on top of slow money. 

Together, they unlock use cases no other jurisdiction has nailed yet – including payment initiation over RTR and standardised API access across both traditional and stablecoin-based rails. But real-time means real-time risk. Brazil had to tap the brakes. Canada doesn’t need that scar tissue – the lesson is already there for the taking. 

6. The registry is just the start 

The Bank of Canada will maintain a public registry of accredited participants – similar to the model under the Retail Payment Activities Act. That gives consumers and businesses a basic trust anchor. But harder questions remain: how will incidents and enforcement actions be surfaced? What will be publicly visible about a provider’s history? How do you avoid creating either a black box that hides systemic problems or a scarlet-letter regime that chills innovation? 

No jurisdiction has fully solved this. Open finance isn’t a one-and-done project. It’s a continuous process of adapting to new risks, behaviours, and technologies. 

7. Manage the ‘thud’ risk 

After nearly a decade of consultation, lobbying, think pieces, and conferences, there’s a real risk that day one lands with a thud – not because it failed, but because phase one is, by design, a first step. Largely read-based data access. Early cohorts of accredited players. Foundations for broader data mobility. 

The message: don’t confuse first release with final state. Don’t declare the project a failure if it doesn’t immediately deliver transformation. Do hold regulators and industry to account for hitting stated timelines, expanding capabilities over time, and keeping competition and consumer power at the centre. This is a multi-year build, not a press release moment. 

8. Execution is where Canada wins or loses 

The narrative is clear. The pitfalls in other markets are well understood. The generational opportunity is real. What remains is the work: standards, accreditation, TPRM, monitoring, liability frameworks, and real-time rails that don’t just move money faster, but move trust and confidence faster too. 

The question is no longer whether Canada will have an open finance framework. It’s whether the execution matches the ambition. 

That gap between policy intent and operational reality is exactly where open finance infrastructure has to do its hardest work. And it’s where the next chapter of Consumer-Driven Banking will be written.