CDR Expansion to Non-Bank Lenders: What It Means for Data Holders and Data Recipients

The Competition and Consumer (Consumer Data Right) Amendment (2025 Measures No. 1) Rules 2025 mark a significant expansion of the Consumer Data Right (CDR) regime in Australia. With non-bank lenders (NBLs) now officially included as Data Holders, and accredited parties continuing to grow as Data Recipients, this change accelerates the movement toward an open, data-driven financial ecosystem.

For existing Data Holders (banks) and newly designated non-bank lenders, this change introduces fresh compliance obligations, infrastructure challenges, and competitive opportunities. Meanwhile, Data Recipients (fintechs, aggregators, and financial institutions) stand to gain broader access to consumer financial data, improving the accuracy and effectiveness of their services.

Key Takeaways:

• Non-bank lenders must now share data under the CDR framework.

• Data Recipients gain expanded access to financial data beyond traditional banks.

• New compliance challenges arise for Data Holders, requiring API development and security measures.

• The industry must prepare for a phased rollout, with large NBLs going first.

For Data Holders: Compliance, Infrastructure, and Strategic Advantage

The introduction of non-bank lenders as Data Holders is one of the most significant shifts in CDR policy to date. Previously, only banks were mandated to share data, but now a wider range of lenders—including BNPL providers, and mortgage lenders —must comply.

What This Means for Data Holders

1. Mandatory API Enablement

   • Like banks, non-bank lenders must now develop and maintain CDR-compliant APIs to facilitate secure, standardized data sharing.

   • A progressive rollout means larger NBLs ($10B+ in loans) must comply first, followed by smaller lenders over time.

2. Operational & Compliance Challenges

   • NBLs must now establish CDR-compliant security, consent, and dispute resolution mechanisms.

   • Compliance with privacy and consumer protection laws adds complexity.

   • Internal data governance improvements will be necessary to align with CDR data-sharing standards.

3. Strategic Opportunities for Data Holders

   • Enhance Customer Experience – Offering CDR-powered financial services can improve customer engagement.

   • Monetization of Data – While direct fees are restricted, compliant data-sharing partnerships with trusted Data Recipients create new business models.

   • Competitive Positioning – Compliance with CDR fosters trust and transparency, setting compliant lenders apart from non-compliant rivals.

     
     

How Wych Can Help Non-Bank Lenders

• CDR API Infrastructure: We provide turnkey API solutions that ensure compliance without the need for extensive in-house development.

• Consent & Compliance Management: Our platform includes secure consent handling, dashboards, and reporting tools.

• Seamless CDR Integration: Whether you're new to CDR or need better compliance support, our solutions help reduce time-to-market.

For Data Recipients: Unlocking New Insights and Expanding Services

For Data Recipients, the inclusion of non-bank lenders into the CDR ecosystem presents a major opportunity to access a broader dataset for credit decisioning, financial wellness products, and AI-driven insights.

What This Means for Data Recipients

1. Access to More Data Sources

   • Previously, only banking data was available through CDR. Now, NBL data expands the landscape, including:

     1. BNPL Transactions – Crucial for credit risk assessments.

     2. Mortgage and Personal Loan Data – Enables better lending decisions.

     3. Alternative Credit Sources – Helps fintechs serve underserved markets.

2. New Financial Insights and Product Opportunities

   • Improved Credit Decisioning – Enhanced data allows for more accurate lending models.

   • Embedded Finance Growth – CDR-backed insights enable tailored product offerings.

   • Better Fraud Prevention – Real-time data sharing strengthens fraud detection.

3. Challenges for Data Recipients

   • Handling More Complex Data Streams – More sources mean greater integration work.

   • Ensuring Compliance in Data Usage – Strict CDR privacy and security standards must be maintained.

   • Building Consumer Trust – Users must be educated on CDR benefits and data control mechanisms.

     
     

How Wych Can Help Data Recipients

• Data Enrichment & Insights: Our platform processes raw CDR data into actionable insights.

• Seamless API Access: We handle API integration complexities, so Data Recipients can focus on delivering value.

• Consumer Consent & Privacy Controls: We provide enterprise-grade compliance tools to protect consumer rights and simplify consent management.

Wych Recommendations

For Data Holders (NBLs)

• Start planning for CDR API enablement and compliance before regulatory deadlines.

For Data Recipients

• Prepare to integrate non-bank lender data into existing CDR pipelines for expanded insights.

For the Industry

• Consumer education and trust-building will be critical in ensuring CDR adoption.

At Wych, we are committed to helping both Data Holders and Data Recipients navigate these regulatory changes. Whether you need API enablement, data analytics, or compliance tools, we have the solutions to support your business.

Get in touch today to learn how we can help you leverage this new era of data-sharing under CDR.