Canada's Open Banking Framework Is Here. Credit Unions, This One's for You.

Are credit unions mandated to participate in Canada’s consumer-driven banking framework?

No. Under the proposed framework, participation is mandatory for designated large banks, but credit unions can choose to opt in. To participate, they must become accredited and comply with the framework’s technical, security and governance requirements.

Canada's proposed Consumer-Driven Banking Regulations landed in the Canada Gazette last week. After years of consultation, the framework is real, the rules are being written, and the clock is ticking.

Here is the first thing credit unions need to know: you are not mandated to participate.

Only specified large banks — those above a retail volume threshold set by the Minister of Finance (this threshold has yet to be defined) — are required to join the framework. Think of it like the UK's CMA9 approach, where the nine largest banks were mandated first. But here's what happened in the UK: almost every other significant financial institution followed voluntarily. Not because they were forced to. Because they had to.

Canada will be no different.

So then why would a credit union choose to participate?

Participation enables credit unions to offer secure, consent-based data sharing with accredited third parties. This allows members to connect their accounts to budgeting apps, accounting platforms, lending services and other financial tools without sharing their online banking credentials.

The screen scraping ban changes everything

Right now, around nine million Canadians are sharing their financial data by handing over their banking login credentials to third-party apps. It's called screen scraping, and it is unregulated, insecure, and — under the new Act — on borrowed time. The legislation includes a prohibition on screen scraping. The timing of when that ban comes into force is still being finalized, but the direction is clear and irreversible.

This appears to be a sensible move by the Canadian Government if its goal is widespread adoption of consumer-driven banking. Australia’s experience demonstrates why. For years, screen scraping has continued to coexist alongside open banking, reducing the incentive for financial institutions, fintechs and consumers to transition to the regulated framework. Only now is the Australian Government considering moving to prohibit screen scraping, following years of slower-than-expected adoption and ongoing frustration across the industry. Canada’s decision to align the transition away from screen scraping with the rollout of its consumer-driven banking framework should provide much stronger momentum for adoption.

When it lands, the only way consumers will be able to connect their accounts to the apps and services they rely on — budgeting tools, lending platforms, savings optimisers — is through the regulated framework via secure APIs.

If your institution isn't in the framework, your members simply won't be able to do it.

For any institution of scale, including credit unions, sitting out is not really a neutral choice. It is a decision to be absent from the financial ecosystem your members are moving into.

Member expectations are already set

Nine million Canadians are already sharing their financial data. They already expect to connect their accounts to apps. The regulated framework doesn't create that expectation, it just makes satisfying it safe and legitimate.

Credit unions have always won on trust and member relationships. Open banking, done right, is an extension of exactly that. Consent-based, member-controlled data sharing, built on a relationship of genuine trust rather than a corporate data extraction model.

The institutions that show up for their members with this capability will deepen those relationships. The ones that don't will find a widening gap between what their members expect and what their credit union can deliver.

The window to engage is now

The consultation period on these proposed Regulations closes August 26, 2026. That is the moment to make your voice heard, to understand your opt-in pathway, and to begin assessing what participation requires.

At Caspian One Open Data, we enable secure, consent-based API data sharing between financial institutions, eliminating the need for screen scraping. As Canada’s consumer-driven banking framework takes shape, we’re already helping financial institutions deliver the type of trusted, interoperable connectivity the framework is designed to support.

If you are trying to work out what this means for your institution, we are happy to talk.

What's your read on this? Are you planning to opt in?

The proposed Consumer-Driven Banking Regulations are currently in a 60-day public consultation period ending August 26, 2026. This is not legal advice. Institutions should seek qualified counsel in relation to their specific circumstances.