Speech by FCAC Commissioner Shereen Benzvy Miller for the Open Banking Expo Canada 2025

Check against delivery. This speech has been translated in accordance with the Government of Canada’s official languages policy and edited for posting and distribution in accordance with its communications policy.

Delivered June 17, 2025, in Toronto, Ontario

Thank you for the invitation to speak at Open Banking Expo. It is a pleasure to be here.

I’ll be speaking in English today, but if any of our francophone colleagues have questions or would like me to clarify anything, please don’t hesitate to come chat with me afterwards. / Je vais m’exprimer en anglais aujourd’hui, mais si les participants francophones ont des questions ou souhaitent des précisions, n’hésitez surtout pas à venir me voir par la suite.

As you have heard, I am Commissioner of the Financial Consumer Agency of Canada, the organization responsible for implementing Canada’s Consumer-Driven Banking Framework.

This is a new role for us. In taking it on, we build on a foundation of: 

• deep knowledge of how the banking industry in Canada functions
• long-lasting and ongoing partnerships and collaboration with stakeholders in the financial ecosystem
• and our research and data-driven insights on consumers’ needs, behaviours, and expectations.

I want to update you on progress we and our partners have made in developing a secure framework for consumer-driven banking, which will protect Canadians, foster innovation, and build consumer trust.

I will also highlight how our approach is grounded in research and data. I want to emphasize that evidence is shaping every step we take.

Consumer-driven banking — or “open banking” — is already part of the lives of Canadians.

A growing number of us share our financial data online with various service providers, including the many fintechs here today.

Canadians appreciate the growing array of products and services offered by fintechs. Thanks to these, the financial industry is more inclusive and efficient than ever.

But …. in this generally positive picture, there is an important blemish.

It won’t surprise you to hear that I am referring to screen-scraping. I know that for many of you, screen-scraping only touches a subset of your business.

But we can all agree that there is a better way to share data, given the host of security, liability, and privacy risks posed by screen-scraping—both for consumers and for the financial system.

FCAC’s research on public awareness and understanding of open banking indicates a significant preference against the use of screen-scraping.

When Canadians were introduced to the concept of screen-scraping and given an explanation of how it works—because most were unfamiliar with it—86% stated they would rather not use it.

This finding highlights the public’s preference for trustworthy, transparent, well-regulated methods for participating in financial transactions online, that ensure privacy, security, and control over their financial data.

Consumer trust

Our international research tells us that trust not only strongly influences consumers' willingness to engage with open banking products and services, but that it’s also key to increasing financial inclusion—because consumers are more willing to share financial data when they trust the system.

We also know from the open banking experience in the UK and Australia that good design—which emphasizes transparency, control, and ease of use—significantly increases consumers’ comfort with data sharing.

And consumer trust is not just essential for individuals—it’s a driving force for business growth and innovation.

A Bank of England study found that even a modest increase in consumer trust made fintechs nearly 4 times more likely to invest and participate in open banking.

This shows that when consumers feel secure about financial innovations, businesses are more willing to invest, expand, and develop solutions that drive the future of finance.

As for consumer protection, our research confirms that most Canadians would not trust sharing their financial data without the safeguards they are used to when dealing with regulated entities like banks, such as:

• protection from identify theft and financial losses due to data breaches or fraud
• and clear complaints-handling and redress mechanisms to make things right if something goes wrong.

It follows that success will be measured by our ability to develop a financial experience that is both seamlessly integrated and highly trusted, so it becomes part of daily life.

The same way we no longer think twice about tapping a screen to connect with loved ones, navigate a city, or take a photo.

We envision a future—not too far off—where consumers can securely share their financial data with trusted providers at the tap of a button, receive personalized insights in real time, and switch between services with the same ease as switching between apps.

So, how do we build consumer trust?

We do it by getting the foundation right.

Foundational elements

The foundational elements are set out in the Consumer-Driven Banking Act that came into force last year. It was an important step in reshaping the financial landscape.

Among other things:

• The Act authorizes FCAC to implement and oversee the Consumer-Driven Banking Framework with a focus on safeguarding consumer interests.
• The Act also grants the Minister of Finance the authority to designate a technical standards body that will be responsible for developing secure application programming interface standards to be used by participants when sharing consumers’ financial data.
• And the Act clarifies some of the requirements—including those related to the in-scope data that can be shared between Framework participants, and to the creation of a public registry of participants by FCAC. These requirements are not yet in force.

Since the Act was adopted, my team has been working closely with the Department of Finance, with industry, and with other stakeholders.

Along the way, we have drawn important lessons from the experience of other jurisdictions, which we aim to capitalize on.

Technical standards and common rules

Under the new Act, FCAC will be responsible for supervising the technical standards body, the external complaints body, and the financial service providers participating in open banking, to ensure they meet their respective obligations.

We are also developing common rules with the Department of Finance. These will address consumer protection interests, as well as privacy, liability, security, national security, and integrity obligations.

The common rules will ensure a consistent application of safeguards and uniformity of practice by financial service providers.

Accreditation

We are also working on developing an accreditation process to ensure only trusted entities can access financial data when requested by a consumer.

Accredited entities will display a common visual identifier. Upon seeing this logo, consumers will be able to trust that they are dealing with a provider that has been authorized to participate in the open-banking ecosystem.

We want to design a process that allows for as many participants as possible, to foster innovation, encourage competition, and promote a more inclusive financial system.

Key desired elements of the eventual accreditation scheme have already been outlined in public policy statements.

They include the need for participants to:

• meet national security safeguards that align with existing financial sector frameworks such as the Retail Payment Activities Act
• provide mandatory reporting of key information to FCAC on a regular basis
• and demonstrate robust cybersecurity and data-protection practices, and an ability to meet common rules on consumer protection.

Together, these elements form the foundation of a robust accreditation framework that prioritizes national security, regulatory transparency, and consumer trust.

Consumer awareness

FCAC is also developing a consumer awareness strategy.

To inform the strategy, we are conducting public opinion research and collaborating with international jurisdictions that have implemented open banking, to learn from their experiences.

One lesson we have already learned is that timely communications—about how open banking works and how it will add value—are vital.

By timely, I mean that wide-spread promotion should ideally take place as soon as there are concrete and compelling applications by participants in the Framework.

The awareness strategy will also be driven by the reality that most consumers have never heard of open banking.

Our research shows that only 9% of Canadians know what it is, and awareness is especially low among seniors, lower income respondents, and women.

Moreover, of the Canadians who have heard of open banking, few understand how it works or how it can benefit them.

We’ll have to demystify open banking and demonstrate through real-life examples how open banking can give them more control, more choice, and more confidence in their financial lives.

Next steps

Today, I have discussed how the Financial Consumer Agency of Canada is moving with partners to establish the necessary foundational elements of Canada’s Consumer-Driven Banking Framework—all based on best practices and evidence-based research.

As for the next steps, we look forward to the next round of legislative amendments being tabled in Parliament by the Minister of Finance. These will be followed by regulations.

And to make sure that industry players understand what’s expected of them, our Agency will issue supervisory guidance.

This guidance will reflect the Agency’s commitment to promoting understanding and compliance within the consumer-driven banking ecosystem.

And to facilitate collaboration, we will establish an advisory committee including members from Federal, provincial, and territorial governments.

Our goal is to deliver a modern financial ecosystem that fosters innovation, enhances Canada’s global competitiveness, protects consumers, and maintains their trust.

Specifically, consumers must trust that they can control, edit, manage, and delete their financial information, and that they can decide when, how, and to what extent their data are shared with others.

Together, we can develop a framework that doesn’t just open doors to innovation but opens possibilities for every Canadian to take control of their financial journey.

My team at the Agency and I are committed and excited about what the future will bring.

We look forward to continuing our collaboration with all of you on developing a framework that will benefit both Canadians and Canada's financial system.

Thank you.