CDR Action Initiation Explained: Use Cases for Payments and Energy Switching

Action initiation is the next big step in the evolution of Australia’s Consumer Data Right (CDR). While the first phase of CDR focused on data sharing, action initiation unlocks the ability to take real actions on a consumer’s behalf — such as making payments or switching service providers — with their explicit consent. This blog breaks down what action initiation is, why it matters, and how it’s changing the game for payments and energy in particular.

What Is CDR Action Initiation?

CDR action initiation allows an accredited third party to perform a task or transaction on behalf of a consumer. Unlike data sharing, which gives visibility, action initiation provides functionality.

Use cases include:

Transferring funds between accounts
Paying bills
Switching energy providers
Setting up or cancelling direct debits

The legislation supporting this change passed in 2024 under the Treasury Laws Amendment (Consumer Data Right) Act.

Payments: A New Way to Move Money

With CDR action initiation, fintechs and digital banks can:

Initiate payments directly from a customer’s bank account
Automate transfers to savings or investment accounts
Streamline bill payments for utilities, subscriptions, and loans

This provides a powerful alternative to traditional payment rails and reduces friction in everyday financial tasks.

For example:

A budgeting app could move leftover cash into a high-interest savings account automatically each payday.
A merchant could collect direct account-to-account payments without relying on card networks.

These use cases are enabled by action initiators operating under CDR and governed by ACCC and OAIC rules.

Energy: Seamless Switching and Savings

Action initiation can also improve how consumers manage their energy services:

Instant switching to a new energy retailer when a better deal is detected
Automated comparisons based on real consumption and usage patterns
Setup and cancellation of direct debit arrangements

For example:

An energy comparison platform could not only recommend a better plan, but switch the user automatically after getting consent.
If a user moves house, a provider could automate connection/disconnection with minimal friction.

These flows significantly reduce effort for consumers and open new service models for energy companies.

Security and Consent Are Built-In

As with all CDR features, consumer consent is central. Action initiation can only occur:

With explicit, informed, time-bound consent
From an accredited provider listed on the CDR Register

All transactions must also comply with the CDR security profile, which includes robust encryption and OAuth 2.0 standards.

Learn more from the CDR Action Initiation Overview.

How Fiskil Supports Action Initiation

Fiskil is ready to support action initiation via our unified CDR API infrastructure. We help fintechs, energy retailers, and software providers:

Build compliant payment and switching flows
Manage user consent with transparency
Access real-time data + enable real-time actions
Reduce regulatory complexity

Whether you want to enable smart payments, account switching, or energy plan automation, our team and tools are built to help you go live quickly and securely.

Visit fiskil.com to get started.

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