Open Finance is changing who owns the customer relationship in Canada. CCM is the battleground most banks haven’t named yet.
On June 27, the draft Consumer-Driven Banking Regulations landed in the Canada Gazette. Part I, Volume 160, Number 26. The comment window closes August 26.
Almost nobody outside a compliance team read it.
I get why. Regulations documents are where good intentions go to become footnotes, and this one runs long. But I think it matters more than the coverage suggested, and not for the reason most people assume.
The public conversation about open banking in Canada has been stuck on one question for about six years now: who gets access to the data. That question is basically settled. The Consumer-Driven Banking Act got Royal Assent on March 26 this year, through Bill C-15, the Budget 2025 Implementation Act, No. 1. The Bank of Canada supervises the framework and keeps the registry, which is a change from the earlier plan to hand it to the FCAC. Schedule I banks can be designated for mandatory participation by the Minister of Finance. Everyone else applies for accreditation.
So the data is going to move. Fine.
Here’s the question nobody’s putting on a slide: once the data moves, who does the customer think of as their bank?
Read access is a bigger deal than it sounds
Phase 1 is read-only. Consumer profile data, account data, balances and transaction history, product terms. It covers deposit accounts, payment products, investment accounts, and lending accounts. Derived data stays out of scope. Write access, the part that lets a third party actually move money or switch an account for you, is Phase 2, targeted for mid-2027 and waiting on Payments Canada’s Real-Time Rail to land first.
A lot of banks have looked at Phase 1 and decided it’s survivable. Read-only, no payments, no account switching. Not much to worry about.
I’d push back on that.
Read access means a fintech app can pull your balances and two years of transactions and build a better monthly summary than the one your bank sends you. The product stays the same. What changes is who explains it. That’s a much lower bar to clear than most banks realize, because the bar is currently a PDF statement that nobody reads and a marketing email that half the customer base filters into a folder they’ll never open.
And once a customer opens an app to understand their own money, the bank behind the account has been demoted to a data source. You still hold the deposits. Somebody else holds the relationship.
The bill is still the most-opened thing you send
I’ve been saying this for a year and I’ll keep saying it, because it keeps being the thing that lands in meetings.
People open their bills. Consistently. Way more than they open marketing email or push notifications, and they open them on purpose, with money on their mind, which is the exact state you’d pay a fortune to manufacture through advertising. Then most institutions treat that moment as a compliance artifact and put their creative energy into the campaign nobody asked for.
That gap has always been an opportunity. Under Open Finance it becomes a defence.
Look at what Banco Carrefour does through our platform in Brazil. Five million personalized messages a month. Through the billing system, not the CRM. That distinction is the whole point. The billing system knows what actually happened to the customer’s money last month. The CRM knows what segment somebody assigned them to in 2023.
When an aggregator can see everything, the institution that explains the money best is the one that keeps the customer. Customer communications management stops being a back-office cost line and starts being the thing standing between you and disintermediation. Which is a long word for “somebody else’s app is now the front door to your customer.”
Mid-market has an actual advantage here, for once
I talk to a lot of Tier 2 and Tier 3 players, and there’s a defeatism that shows up whenever regulation comes up. The big five have more people, more budget, more lobbyists, so the assumption is they’ll handle this better.
Maybe. But scale cuts both ways.
RBC and TD have to change communications across dozens of product lines and legacy systems, with a governance process that treats a statement template change like a minor act of Parliament. A credit union or a mid-sized lender can rewrite how it talks to customers in a quarter. That’s not a small edge in a window this short. It might be the only structural advantage mid-market has had in a decade.
The catch is that most mid-market institutions can’t actually make that change quickly either, because their communications are welded into a core banking system nobody wants to touch. So the advantage exists on paper and evaporates in practice. I’ve watched it happen.
What I’d actually do between now and August 26
Read the draft regulations. Or have somebody read them and brief you in a page. The comment period is real, you submit through the Canada Gazette site, and mid-market voices are badly underrepresented in these consultations compared to the banks that can afford a policy team.
Then go pull your own statements. Not the spec document. The actual thing that goes to customers. Read it the way a 34-year-old with a chequing account and a car loan would read it. If your answer is “well, it’s compliant,” you’ve just described the opening a fintech is going to walk through in about fourteen months.
Fast Movn is a Canadian technology company, based in BC, with a platform that’s been validating and personalizing billing communications at scale for years. Vivo runs 35 million validations a month through hiperValidation. hiperCCM is what turns those communications into something a customer actually reads.
Open Finance is going to decide who owns the customer conversation in this country. I don’t think it’ll be decided by whoever has the best API.
So who’s explaining your customer’s money right now? You, or an app?
Sources referenced in this piece
- Canada Gazette, Part I, Volume 160, Number 26: Consumer-Driven Banking Regulations (June 27, 2026)
- Consumer-Driven Banking Act, Royal Assent March 26, 2026, via Bill C-15, Budget 2025 Implementation Act, No. 1
- DLA Piper, “The new Consumer-Driven Banking Act explained” (April 2026), for Phase 2 write-access timing and the Bank of Canada supervisory role
- Payments Canada, Real-Time Rail launch timing