2025银行与金融业消费者数据权的未来（第六版）

CHARTING THEFUTURE OF THE CONSUMER DATA RIGHTFOR BANKING & FINANCE 6th Edition - September 2025 Supported by “The future isalready here - it’sjust not evenlydistributed yet.” — William Gibson FOREWORD BY DR BILL ROBERTS I am honoured to have been invited to write this foreword to the latestedition of the Australian Open Banking Ecosystem Map and Report byFinTech Australia, supported by Mastercard. I have had the privilege of being involved in the way open banking is beingadopted in many jurisdictions. I led the design and implementation of theworld’s first Open Banking framework at the UK Competition and MarketsAuthority (CMA); I am a Fellow at the Cambridge University Judge BusinessSchool Centre for Alternative Finance where I run ouronline course on OpenBanking for regulatorsaround the world; and I advise the Bank of Thailandon its Your Data project. DR BILL ROBERTS From my experience, it seems to be not uncommon for Open Bankingimplementations to lose momentum after a couple of years and progressgrind to a halt. This certainly happened in the UK when Open Bankingimplementation was nearing completion, and the banks felt they had doneall that they had been mandated to do under the CMA Order. Fellow at theUniversity ofCambridge JudgeBusiness SchoolCentre forAlternative Finance I visited Australia earlier this year, and it appeared that something similarhad happened with your Consumer Data Right (CDR). This led to a reset inthe CDR in August 2024 by the then Assistant Treasurer Minister StephenJones, where policymakers and the industry have taken stock, reassessedpriorities and are now working to fix the problems that have held backconsumer and business take-up. I noted the following problems/fixes: Make it easier for small business accountingThe user experience for SMEs has not been great, particularly the difficulty ofunlocking the potential of cloud accounting software, which, incidentally,drove UK SME adoption to around 25% very soon after we launched OpenBanking in the UK. These issues were not the intended consequences of theprivacy regime. Once the new rules are in place, I believe you will see a surgein SME adoption, since close to 2 million small businesses currently havecloud accounting: they just can’t enable its true potential to save them timeand money and faster access to business finance. Transition off screen scrapingThe continuing use of screen scraping by third-party recipients and the disincentive to switch to Open Banking is slowing adoption. Several of thebanks I talked to intend to introduce two-factor authentication forconsumers wishing to bank online. This won’t eliminate screen scraping, butit could reduce it massively, encouraging third parties to adopt CDR for theirpersonal finance management and credit applications, again, triggering asurge in adoption. Simplify data standards changesFrequent changes to standards were causing significant problems for DataHolders. Some of the changes following Dr Oppermann’s appointment arevery encouraging, but there might be difficulties ahead given the maturityof the standards and the changes needed. All of these need to be fixed, not just for the momentum to return, but foradoption to truly accelerate. But, from my perspective, what else will it takefor CDR to achieve its full potential? All the readers of this report get it, but it has to be admitted that the CDR isnot a major vote-winner. Indeed, as is the case with driverless cars, when youfirst describe the concept, people often think first of the risks if somethinggoes wrong rather than the benefits it can bring. Open Banking has saved billions of pounds in the UK, and it could do thesame job in Australia. This is a powerful incentive for the government to fixthe remaining problems in the CDR ecosystem in a timely manner. So, if the industry wants to get the CDR the political backing and attention itdeserves, then one quick win could be to draw attention to the benefits togovernment that it can bring by, for example, reducing the costs ofcollecting taxes, driving productivity and cutting bills, and ensuringpayments and tax rebates are going to their rightful recipients, to name afew. On the subject of incentives, let’s look at banks. I mentioned earlier thatmomentum in the UK faded as the final stages of implementationapproached. This was partly because most of the UK banks saw OpenBanking as a threat rather than an opportunity: a cost of compliance ratherthan an investment in the future. This was perfectly reasonable, as the whole point of Open Banking was toput competitive pressure on banks from newer and nimbler providers of thesame services, so banks had every incentive to resist its introduction and doonly as much as they were mandated to do. Now, while I greatly admire the skill of regulators, markets where they arewell-functioning do a much better job of allocating resources. So, is there away of incentivising the participation of banks rather than requiring it