Canada is a late mover in open finance. That's an advantage - if the Bank of Canada designs the implementing regulations right.

Australia's Consumer Data Right launched in 2020. By the end of 2023, 0.31% of Australian bank customers were actively using it.

The United States took the opposite approach - market-led, high adoption, and a liability structure that nobody agreed in advance.

Canada has a rare opportunity to avoid both failure modes.

Invela's white paper examines the legal and regulatory landscape - the CDB Act, OSFI B-10, OSFI B-13, and the Retail Payment Activities Act - and offers two high-level recommendations for the Bank of Canada's implementing regulations.