This article is a collaboration between Quill Peak, Studioworks and Open Data Australia - all of us keenly interested in the success of the CDR in Australia.

At the beginning of July 2021 open banking went live in Australia and all ADIs were supposed to be able to share data and meet their obligations as Data Holder. At the time we published a summary of the state of CDR highlighting how many ADIs were ‘still on the journey’ and how few organisations were active as data holders or data recipients.

All banks that were ‘still on the journey’ to becoming active Data Holders were required to submit a plan to the ACCC by the end of July outlining how they would meet their CDR obligations.

So what’s changed since then?

To download larger versions of these images, click the following links: 2 September 2021, 1 July 2021

The good news is that over the last two months, the number of active Data Holders has increased by 94%, with another 15 ADIs set up to share data using the CDR.

This leaves 47 ADIs still on the journey. A further twenty-one ADIs have been given exemptions for up to two-and-a-half years to meet their data holder obligations.

This level of new active Data Holders represents steady progress and it’s looking likely that the vast majority will be active before the end of the year.

The ACCC has published a rectification schedule indicating when they expect each of the remaining ADIs to become active.

However, when we look at the Data Recipients, there’s been no movement at all in the last two months! We still have just five different entities who are Active and twelve who are Accredited.

Although more data holders have become active, we have not yet seen the growth of ADRs using CDR data to deliver value to consumers.

So the question is whether there is a pipeline of propositions being developed which use CDR data.

To help answer this question Quill Peak is conducting a CDR Pulse Check(now complete). – a quick survey to obtain insights on the pipeline of CDR-data enabled propositions which will be brought to market and the perceived barriers to bringing them to market.

Based on early responses to the Pulse Check, organisations’ perceptions of lack of customer demand are inhibiting their development of propositions. Are we facing the same dilemma the early smart phone makers encountered where consumers weren’t demanding smart phones because they didn’t have a good understanding of the benefits that smart phones could provide?

CDR has the potential to enable new categories of products that consumers have not experienced previously and so a certain boldness will be needed to create those new categories and lead consumers with the art-of-the-possible.

In addition, organisations are suggesting that frequent changes to the rules and standards are also getting in the way of bringing propositions to market.

Will the introduction of intermediaries and new classes of data recipient reduce the complexity and cost of becoming a user of CDR data and see a growth in customer propositions coming to market?

Whether you are in a designated sector for CDR, or in one to which CDR might be applied following Treasury’s Strategic Assessment, or you are developing propositions that use CDR data, your view is valuable.

Click on the following link to contribute your views: CDR Pulse Check (now complete – see the report here).

Paul Wiebusch
Associate, Quill Peak Consulting

Paul is a consultant specialising in Open Data, the Consumer Data Right and Open Banking.

David Giddy
Principal, Quill Peak Consulting

David is the Principal of Quill Peak Consulting, a boutique consulting firm specialising in Open Banking and the Consumer Data Right. See  to learn more.

Robin Scarborough
Co-Founder, Studioworks



Jamie Leach
Founder, Open Data Australia

Robin is a consultant specialising in the development of new customer propositions and co-founder of Studioworks, a community of independent agencies and consultancies delivering pioneering work for their clients. See to learn more

Open Data Australia is a not-for-profit organisation and the Australian member of the Global Open Data Institute network. See to learn more