Canada Enacts Open Banking Framework Under Bill C-15
Bill C-15 establishes a legal foundation for data sharing, with rollout dependent on standards, accreditation, and implementation.
Canada has formally moved from policy discussion to legislative action with Bill C-15 receiving Royal Assent on March 26, 2026. As part of the Budget 2025 Implementation Act, No. 1, this legislation repeals and replaces the earlier Consumer-Driven Banking Act (CDBA) that had received its first Royal Assent in June 2024, and enacts a comprehensive new CDBA that establishes a fully operational legal foundation for a consumer-permissioned data sharing framework.
This milestone does not mark the beginning of the open banking journey in Canada but rather a decisive step forward toward a more substantive regime. Bill C-15 takes that framework further by providing a more complete legal foundation for consumer-permissioned data sharing and formalizing the right for consumers and businesses to securely access and share their financial data with authorised third parties within a regulated ecosystem..
Oversight and implementation have been delegated to the Bank of Canada, which will supervise the technical standards body designated by the Minister of Finance, and will be responsible for accreditation, system integrity, and alignment with broader payments modernisation efforts, including Canada's forthcoming Real-Time Rail infrastructure.
Scope of Data and Phased Functionality
The scope of data under the initial phase covers a wide range of financial information, including:
customer identity and KYC-related data
deposit accounts and payment products
registered and non-registered investment accounts
lending products such as credit cards and lines of credit
All data sharing will be consumer-permissioned. The framework begins with read access only. Write capabilities, such as payment initiation and account switching, are targeted for a second phase expected around mid-2027, contingent on the successful launch of Canada's Real-Time Rail payments system, which is anticipated in 2026.
Participation is structured through a phased model distinguishing between mandated and optional entities. Large banks meeting specified thresholds will be required to participate from the outset, while provincial credit unions and crown corporations that act as banks may opt in, subject to meeting accreditation and compliance requirements. A key design principle is reciprocity, ensuring all participants both provide and receive data under consistent rules.
What Still Needs to Be Built Before Go-Live
While the legislative foundation is now in place, the framework is not yet operational. Several critical components remain to be defined before live data sharing can begin, including:
finalisation of technical standards, particularly APIs and data formats
establishment of an accreditation regime for third-party providers
clarity on liability allocation and consumer consent mechanism
The focus now shifts to execution, led by the Department of Finance and the Bank of Canada, with continued coordination across industry participants. The government has allocated up to CAD 19.3 million to the Bank of Canada over two years for implementation, with approximately CAD 5 million per year in ongoing administrative costs thereafter.
Signals from Stablecoin Regulation and Payments Evolution
Alongside the CDBA, Bill C-15 also enacts the Stablecoin Act within the same legislative package, signalling a wider shift in how Canada is approaching innovation in payments and digital assets.
What This Means Going Forward
In summary, Royal Assent of Bill C-15 provides long-awaited legal substance not merely legal clarity to Canada's open banking ambitions. The direction is firmly set; however, significant regulatory work, technical standard-setting, and ecosystem coordination remain before the framework becomes operational. The pace and effectiveness of that implementation will determine how quickly Canada's consumer-driven banking system moves from statute to reality and, over time, toward a broader open finance environment.
