Accreditation working group meeting 1 – July 5, 2022

This discussion guide is provided to assist working group members in preparing for the meeting.

For questions or comments, please contact obbo@fin.gc.ca.

On this page:

• Discussion guide
• Outcomes

Discussion guide

Objective

Accreditation is the process through which organizations would demonstrate their fitness to participate in the open banking system. The aim of this working group is to draft an accreditation framework to recommend to the government.

In their final report, the Advisory Committee on Open Banking (the Committee) noted that the crucial challenge in establishing an accreditation framework is to strike the right balance between promoting entry to the system for smaller participants while maintaining security and protection for all participants. Open banking will only provide value to consumers and the economy if service providers are able to participate and develop new services and products. At the same time, consumer trust in the system underpins participation and can be lost quickly if something goes wrong.

Approach and timelines

Meetings will be held approximately every three weeks. Members are encouraged to review the following material in advance of meetings:

• Canada's Digital Charter: Trust in a digital world
• Final Report, Advisory Committee on Open Banking
• Terms of reference for the open banking working groups and steering committee
• Annex A – Timeline of accreditation working group topics

The open banking lead, with support from the Department of Finance Canada (the Secretariat), will distribute documents guiding the discussion for each meeting which will also be available on the open banking implementation page. Members may also be asked to draft material for discussion.

Accreditation working group topics and timeline

Discussion

1. Are there other topics that should be considered by the accreditation working group which were not captured in Annex A?
2. What are your views on the proposed timeline and cadence of the work plan?

Accreditation criteria categories

The Committee recommends that the accreditation criteria be sufficient to demonstrate that the organization seeking accreditation is able to comply with the common rules related to liability, privacy and security, including having sufficient financial capacity to ensure consumers are protected in the event of loss.

As a starting point, the following accreditation criteria categories are proposed:

Discussion

3. Are there other categories for which accreditation criteria should be developed?
4. Is there any information that may be challenging to provide?
5. Are there initial views on what elements should come under each of the above criteria?

Annex A – Timeline of accreditation working group topics

Theme 3: Accreditation process

Timeline Oct. to Dec.	Topic	Outcome
Meeting 7	Time to accredit/ Refreshing accreditation/ Costs of accreditation	Recommendations on key aspects of the accreditation process as they pertain to administrative measures
Meeting 8	Revocation of accreditation/Appealing an accreditation decision	Recommendations of key decisions related to accreditation which effect ecosystem participation

Outcomes

Accreditation working group topics and timeline

Discussion 1

Are there other topics that should be considered by the accreditation working group which were not captured in Annex A?

• There was general consensus that the proposed topics for the accreditation working group were appropriate. 
• The interdependence of the accreditation stream vis-à-vis the other working groups (liability, privacy, security) was noted.

Discussion 2

What are your views on the proposed timeline and cadence of the work plan?

• There was a general consensus that the proposed timeline and cadence of meetings for the accreditation working group are appropriate.
• It was noted that the cadence and timeline may need to be adjusted based on progress. Financial capacity was noted to be a complex topic which may require additional time.

Accreditation criteria categories

Discussion 3

Are there other categories for which accreditation criteria should be developed? 

• Some participants raised environmental and social governance (ESG) and anti-money laundering (AML) as potential accreditation categories. No consensus was reached on the addition of these categories.

Discussion 4

Is there any information that may be challenging to provide?

• The importance of proportional application of the accreditation criteria was noted. In particular, there was interest to explore different tiers of accreditation in upcoming meetings.
• A participant noted that financial capacity may be particularly challenging. Barriers with respect to obtaining cyber insurance were noted.

Discussion 5

Are there initial views on what elements should come under each of the criteria?

• Participants noted that a dispute resolution mechanism should be included under internal governance requirements.
• Participants noted that existing privacy and security laws, regulations and standards could be leveraged within the accreditation framework.

Accreditation working group attendees