Five Years of the CDR: What We've Learned and What’s Next

It’s been five years since Australia officially launched the Consumer Data Right (CDR), and in that time, we’ve witnessed the makings of a modern, open data economy, albeit with a few rain checks and detours. From legislative firsts to sector-wide rollouts and a fresh reset, the journey of CDR has been measured. As we cross the midpoint of 2025, the signs of momentum are becoming clear: legislative clarity, stronger infrastructure, and a wave of real-world use cases are setting the stage for CDR's next phase.

The Journey So Far

2019: Laying the Groundwork

In August, the Treasury Laws Amendment (Consumer Data Right) Act 2019 gave legal life to CDR, embedding it within Australia’s competition framework.
The banking sector was the first to be designated, setting the foundation for Open Banking.

2020: Open Banking Goes Live

February saw the introduction of the first CDR Rules, establishing operational guidelines for data holders and recipients.
By July, major banks were sharing consumer data under CDR, officially launching Open Banking in Australia.

2021: Expanding the Ecosystem

Non-major banks came online in July, widening consumer access and competition in financial services.

2022: New Sectors Join the Fold

In November, the energy sector was added, enabling data sharing across electricity and gas providers.
December brought a major announcement: non-bank lenders would be next, pointing toward a future of Open Finance.

2023: A Strategic Reset

Assistant Treasurer Stephen Jones hit pause on CDR’s expansion to refocus priorities. The aim was to streamline the regime and concentrate on high-value use cases like energy switching, consumer lending, and SME access - deliberately stepping back from personal financial management (PFM).
Regulatory enforcement intensified, and exemptions were introduced for data holders with mature privacy and data storage practices.

2024: Action Initiation Becomes Law

In August, legislation was passed enabling "action initiation" — a powerful upgrade allowing consumers to instruct accredited parties to initiate transactions or switch services on their behalf.
A formal rollout timeline was set for non-bank lenders, with data obligations beginning from July 2026.

2025: New Leadership, Renewed Focus

In May, Dr Daniel Mulino was sworn in as Assistant Treasurer, and Dr Ian Oppermann began his two-year term as Chair of the Data Standards Body.
In June, the ACCC fined NAB $751,200 for incorrect credit limit data disclosures, one of the largest enforcement actions under CDR to date.

What’s Next: A Look Ahead

So, where does CDR go from here?

We’re entering a pivotal chapter. Action initiation, often touted as the bridge between Open Banking and Open Finance, is now law but rules or standards that will make it a reality are yet to be determined.

Meanwhile, the rollout to non-bank lenders signals a deeper transformation. As product and consumer data obligations phase in through 2026 and 2027, fintechs and digital lenders will face both new opportunities and compliance hurdles.

But for all its promise, CDR still has growing up to do. Regulatory alignment, ecosystem simplification, and meaningful adoption by end users remain critical. And that’s where companies like Fiskil come in.

CDR’s Next Frontier

At Fiskil, we see CDR as more than a compliance exercise - it’s an engine for product innovation, customer empowerment, and industry-wide agility. The next five years will be defined by:

Actionable Interoperability: Connecting banking, energy, and credit data through unified APIs for smarter decision-making.
Embedded Use Cases: Powering seamless in-app experiences like auto-switching energy plans or initiating loan applications.
Trust by Design: Elevating data governance and consent mechanisms (like the recent app to app redirection update approved by the Data Standards Chair) to earn and keep consumer trust.
Industry Resilience: Building adaptive infrastructure that evolves with regulation, so our customers can focus on innovation.

With the technical foundation in place and strategic momentum returning, the future of CDR looks promising. We’re here to help our partners lead it.

Interested in building with the CDR? Get in touch with Fiskil to see how we can you comply and compete with open data.

Posted by

Coco Armstrong

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