Global Open Finance Lessons for Canada’s Rulebook

Open Finance Policy Development | May 22, 2025

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Global experts show why open finance needs clear rules, pricing, and trusted governance

On May 15, 2025, the Cambridge Centre for Alternative Finance (CCAF) hosted a webinar, “Open Finance in Practice: Implementation, Liability & Monetisation” with experts from Thailand, Rwanda, India, the UK, and Asia-Pacific who shared what's working and what's not, based on their practical experience. Open finance is progressing globally but real world experience shows that it is not just about technology or APIs, and successful implementation depends on clear rules, trusted governance, and strong infrastructure.  These insights are especially relevant now as Canada prepares to implement its own open banking system in 2026.

5 Key Takeaways

1. Regulation Moves Faster Than Voluntary Participation

Sanjay Janeja, Open Banking Lead, CCAF:

“Our data shows that regulation-led models support faster implementation and broader data sharing.”

CCAF’s Global Regulatory Innovation Dashboard (GRID) shows that countries with clear regulatory mandates, like Brazil and Australia, have progressed faster than those relying on voluntary participation. India in contrast, moved slowly at first without regulatory mandates. Canada risks similar delays unless its upcoming rules are clear, enforceable, and consistent.

2. Governance Must Be Defined Early

Denise Dias, Regulatory and Supervisory Consultant:

“Governance is the soul of open finance.”

See:  The Transition Towards Open Finance in the UK

Governance critically defines who sets the rules, allows the accreditation of participants, and resolves disputes. Rwanda is building shared oversight between its financial and telecom regulators. Countries that define this early see smoother adoption. Canada's future governance structure needs to include clear roles for regulators, industry, and consumer protection agencies.

3. Liability Needs a Rulebook

Rafael Mazer, Director, Fair Finance Consulting:

“Consumers should not have to wait for firms to assign blame before they are made whole.”

As more parties exchange financial data, legal clarity is paramount. The UK mandates reimbursement even before liability is settled. Oman and UAE require indemnity insurance for open finance participants. Canada needs to define who is liable, under what conditions, and how disputes will be resolved before open banking go live.

4. Pricing Must Be Transparent and Fair

Rafael Mazer:

“This is where the claws come out.”

See:  Open Banking: Revolutionizing Financial Data Sharing

Camilla Bullock, CEO, Emerging Payments Association Asia:

“You cannot grow the pie if the small players cannot afford a slice.”

Thailand uses free access for consumers and capped pricing for commercial use. Brazil allows a set number of free requests per user. These models keep access open for small fintechs. Canada should consider following suit to avoid anti-competitive pricing that could exclude new entrants.

5. Local Context Shape Design

Pamela Umutesi, Lead for Open Finance, National Bank of Rwanda:

“Let your local context guide how you implement.”

Thailand focused on non financial data first because the infrastructure was already in place. Rwanda’s model prioritizes mobile money. Canada of course is considering its own requirements, including provincial data laws, legacy banking systems, and regional financial access gaps. Bottom line is that a one-size-fits-all model that works abroad will not necessarily work elsewhere.

Global Comparison Table

The table below primarily covers open banking implementations, with some jurisdictions extending toward open finance (Brazil, India, Thailand).

See:  BoE Report: Open Banking Boosts Productivity, Competition

This is an important distinction because open banking generally refers to access to 'bank account data' which is often mandated for regulated institutions.  While Open Finance expands beyond banking data to include insurance, investments, pensions, government data, mobile money, and more.

What Canada Must Do Now

Canada has committed to implementing open banking but full rollout isn't expected until 2026. In June 2024, the Department of Finance enacted the Consumer-Driven Banking Act, the legal framework for open banking, and appointed the Financial Consumer Agency of Canada (FCAC) as the authority responsible for implementing, overseeing, and enforcing the framework. Final rules on liability, pricing, and participation are still under development.

See:  CSA Seeks Industry Input on Data Portability Consultation

Countries that wait too long or rely only on voluntary models are playing catch-up.  NCFA supports an open finance framework in Canada that protects consumers, enables competition, and accelerates innovation. Canada should learn from the world's most successful open finance systems, which are defined by clear regulation, fair pricing, and shared governance.  As the CCAF’s global tracker and research show, clear rules work. Delay does not.

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

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