The near term opportunity is strongest where better data cuts underwriting time, verification cost or manual work. If those services do not generate repeat use, payment initiation becomes more important to the commercial case.

A staged rollout tied to transaction risk and proven operating performance would let Canada add useful functionality without treating every payment use case the same.

Consent, security, liability and consumer redress need a firm baseline. Other obligations should track the activity, exposure and risk a participant creates. If smaller firms carry costs that do not reduce material risk, the framework can weaken the competition and consumer choice it is meant to support.

Commercial data sharing can keep growing without a settled federal rule. The competitive issue is who controls access terms. Continued uncertainty favours firms with the scale to negotiate bilateral arrangements and absorb repeated integration costs.

Paid services make sense when they deliver functionality, service levels or risk controls beyond the baseline. Charging for ordinary access too early can weaken fintech economics and reduce the demand needed to support a durable market.

More data can improve advice, comparison and underwriting. Action becomes more valuable when it removes a meaningful customer step. The case for wider authority should be judged against the friction it removes and the additional fraud, consent and liability risk it creates.

Standards need to adapt faster than legislation without giving the largest participants control over market access. Funding, technical administration, consumer representation and statutory enforcement should remain clearly separated.

The key control is authority. Customers need clear limits on what an agent can do, for how much, for whom and for how long. Auditability, revocation and liability become more important as autonomy increases.

Brazil shows the value of pairing data access with an action customers already understand and use frequently. Canada does not need the same payment model, but its early data services still need to solve problems often enough to create repeat behaviour.

Wider access is most useful when the additional data changes a financial decision or removes customer friction. Scope should follow clear use cases, with common identity, consent and liability controls reducing the cost and risk of expansion.