Consumer Data Right access: 3 pathways to participate in open banking with TrueLayer

There are new access arrangements for the Consumer Data Right (CDR), meaning more businesses can participate in open banking. Here’s how TrueLayer can help.

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TrueLayer is a fully fledged participant in the Australian open banking ecosystem having been authorised by the Australian Competition and Consumer Commission (ACCC) as an unrestricted Accredited Data Recipient (ADR).This means that TrueLayer can guide you through the process to obtain your own accreditation. Alternatively, TrueLayer can allow you to access CDR data via one of the new tiered access arrangements which, following Treasury's Rules Consultation, have been confirmed by the Government.There are now five CDR access options, however, two of them appear to have some unresolved issues, namely the Affiliate/Sponsor and Trusted Adviser models.So how should you go about accessing CDR data? And how can TrueLayer support you in that journey?We’ve broken down the most interesting and relevant access arrangements, so you can understand how you can participate in open banking in the right way for your business.TrueLayer is focusing on these three alternatives:
  1. Unrestricted ADR
  2. CDR Representative
  3. Insights Disclosure
Here’s some more information about each of these three access models:

1. Obtain your own authorisation as an unrestricted Accredited Data Recipient (ADR)

Becoming authorised as an unrestricted ADR opens up the whole open banking ecosystem, but it can also be a lengthy and expensive process, taking up to six months (or even longer if your use case is complex) and potentially requires internal process improvements to meet the ACCC's requirements. If becoming an ADR is the right go-to-market strategy for you, TrueLayer can guide you through the accreditation process. Contact us to find out how and read our guide to find out more about how the accreditation process works.Once you become an ADR, you can work with TrueLayer as your outsourced service provider to collect the data and benefit from our APIs.

2. Become a CDR Representative of TrueLayer as your Principal

An alternative way to access full CDR data is to become a CDR Representative of TrueLayer as your Principal. This access model has lower barriers to entry. It also significantly reduces your cost and compliance burden as TrueLayer is liable for dispute resolution and compliance with the rules. This model allows full access to the CDR data that TrueLayer collects for you, however, you must disclose this arrangement to your customer as a background detail.There are security controls and data safeguards that apply. You cannot use the data other than in accordance with your contract and you cannot enter into an arrangement with another Principal. TrueLayer sees interesting potential for the CDR Representative model to be implemented in Australia in a similar manner to the Agency model in the UK, where we already have a world-leading compliance program and over five years of experience. With more than 50 agents in the UK alone, TrueLayer understands the necessary compliance requirements for such an arrangement to be mutually beneficial and robust.This access model could be interesting for TrueLayer’s global partners seeking to go-to-market in Australia.In the fullness of time, once the business case is proven, a CDR Representative could progress to apply for full accreditation as an ADR and TrueLayer will be there to help at every step.

3. Verify consumer data with Insights Disclosure

The third pathway to market allows you to verify specific pieces of consumer information without the need for accreditation or representation. Despite its name, this model is designed for verification of discrete and simple pieces of information, rather than personalised or derived insights. You can use this particular arrangement to:
  • Identify your customer
  • Verify a customer's account balance
  • Verify a customer's income and expenses
This arrangement allows for the outsourcing of the collection of the above CDR Insights to TrueLayer and, with the consumer’s consent, disclosure of those insights to you as the third party. The third party can be a financial or non-financial business making this access model interesting for payments providers and lenders as well as landlords, telco and energy retailers, and others. Find out more about outsourcing the collection of CDR insights.

Understand how the open banking ecosystem works

The CDR is evolving all the time. And with it, open banking is evolving, too.Find out more about these pathways to market here, and how you can leverage TrueLayer’s accreditation.Or stay on top of the latest legislative and regulatory changes, and TrueLayer news, with our blog.

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