Karsten Wenzlaff, Advisor
August 26th, 2025
Karsten Wenzlaff is a Crowdfunding and Fintech Expert from Germany. He is Secretary-General of Digit[...]
The Next Open Banking Battle Is Decision Intelligence
August 6, 2026 | NCFA Insight | Open Banking Open Finance And Data Sharing, Artificial Intelligence And Data, Competition And Market Structure
Who Captures the Value Created Above Financial Data Access
Canada’s open banking framework will help customers move financial data between approved providers. The larger commercial opportunity is what firms can do with it: improve credit decisions, spot fraud earlier, give useful financial guidance and respond faster when customers need help.
Secure access is essential, but access alone won’t determine which firms create the most value.
On July 31, 2026, Scotiabank introduced three knowledge agents through Scotia Intelligence. More than 71,000 employees have access to the bank’s AI capabilities, which had generated 14 million actions since launching in March 2026.
The agents help employees find approved information on delivery standards, procurement, travel and expenses. They aren’t open banking products. They show how a large bank is learning to govern information, connect it to AI systems and use those systems inside daily workflows.
Banks shouldn’t judge AI only by model accuracy. The stronger measure is whether it improves a real financial decision, such as approving credit, detecting fraud or helping a customer act sooner.
Canada’s Rules Stop At The Data Layer
Canada’s proposed Consumer-Driven Banking Regulations establish requirements for accreditation, consent, security, liability, technical standards, complaints and Bank of Canada oversight. The framework is intended to replace screen scraping with regulated API access.
NCFA’s Canada open banking rules guide tracks the remaining work across participation, authentication, consent records, security and implementation.
Participating institutions must share prescribed account, balance, transaction and product information when a customer requests it. They generally don’t have to share data that has been commercially enhanced to increase its usefulness or value.
A customer may transfer transaction history to another provider while leaving behind the bank’s internal risk scores, fraud patterns, behavioural classifications and service recommendations. The records can move with permission. Much of the interpretation may stay behind.
That gives firms room to compete through better models and products. It also means data portability may do less to weaken an incumbent bank’s advantage than many open banking advocates expect.
Credit, Fraud And Cash Flow Will Show What The Data Is Worth
An API connection has little value on its own. The information becomes commercially useful when it improves an outcome that a customer or business can measure.
Cash-flow underwriting could give lenders a more current view of whether a borrower can repay. Incoming revenue, recurring expenses, balance patterns and payment obligations may reveal more than a static credit file.
That could help small businesses, gig workers and borrowers with limited credit histories. It could also produce faster denials, intrusive classifications or pricing that customers don’t understand. More data does not automatically produce a better result.
Fraud systems could review activity across connected accounts instead of assessing one transaction in isolation. A small-business platform could warn about an approaching cash shortfall. A lender could use verified income and spending patterns to assess eligibility or limits. A financial app could identify expensive debt, idle cash or recurring charges that warrant action.
NCFA’s open banking commercialization roadmap identifies cash-flow tools, embedded credit, onboarding and treasury services as potential businesses built above data access.
For a broader view of the companies, regulation, infrastructure and opportunities developing around financial data access, explore NCFA's Open Banking market intelligence.
Did the decision reduce fraud losses, improve credit performance, help a customer avoid a fee or resolve a problem sooner? A more accurate model matters only when it produces a better result.
Data Portability May Still Leave Banks In Control
Open banking is expected to reduce the advantage banks receive from holding customer account data. It doesn’t give every participant the same ability to use that data.
Large banks already have long account histories, established distribution, compliance teams, capital and multiple products. They can combine outside data with information held across deposits, cards, loans, investments and customer-service interactions.
Scotiabank’s deployment shows how quickly an incumbent can build governed AI workflows before shared financial data becomes widely available. Its announcement doesn't unveil any details about how the knowledge agents may connect or interact with consumer-driven banking, so any future use remains unconfirmed.
Fintechs have a different opportunity. A specialist may understand one customer group or financial decision better than a universal bank. It can concentrate on cash-flow underwriting, fraud detection, financial guidance or small-business treasury without carrying the same legacy systems.
Infrastructure providers may supply the data normalization, identity, consent, categorization and scoring tools used by both sides. A fintech could develop the intelligence, a bank could provide the balance sheet and distribution, and an infrastructure company could connect the workflow.
That arrangement may create strong suppliers without changing who owns the customer relationship.
Competition perspective is that Canada should measure whether independent providers gain durable customer relationships, whether switching produces better products and whether smaller firms can compete without becoming feature suppliers to incumbent banks.
Customers Need Rights Over How Their Data Is Used
Permission to access financial data should not become unlimited permission to infer, classify and act.
A customer may share transaction history so an app can prepare a budget. The same records might also be used to infer financial stress, employment stability, likely life events or willingness to accept a higher price. Those uses carry different consequences.
The stakes and liability rise when an inference affects credit, account access, fraud controls, pricing or financial guidance.
A statistically strong model can still produce unwanted results that rely on incomplete data, reproduce unequal outcomes or optimize for the institution rather than the customer. Fraud systems can block legitimate transactions. Cash-flow models can misread irregular income. Personalized recommendations can become disguised sales prompts.
Banks and fintechs need clear purpose limits, explanations for consequential outcomes, ways to correct inaccurate information and human review where the impact justifies it. They also need to establish who is accountable when data, scoring and distribution come from different providers.
This differs from the authorization problem reviewed in AI payments consent and liability. That issue concerns whether an AI agent can legally authorize a payment. Decision intelligence concerns how permissioned data is interpreted and how those interpretations affect the options, prices and outcomes presented to a customer.
Canada is building open banking around secure access and customer control. The next competitive issue is whether banks and fintechs can turn shared data into better decisions without making those decisions harder to understand or challenge.
The firms that succeed will need to prove that their decisions are commercially better and that customers receive a fair share of the benefit. Otherwise, financial data may become more portable while market power remains largely where it is today.
Talking Point
If customers can move their financial records but not the intelligence created from them, how much competitive power does open banking really transfer?
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: [www.ncfacanada.org](http://www.ncfacanada.org)
 |  |  |
|---|---|---|
 |  |  |
Leave a Reply