Issue 49: A detailed look at the CDR Reps
While it's a quiet time for the Consumer Data Right and we get closer to the end of the year, I thought it would be an excellent time to take a detailed look at the CDR Representatives.
CDR Representatives are a growing part of the CDR
The Consumer Data Right (CDR) framework offers a flexible accreditation pathway known as the CDR Representative model. A CDR Representative is a business authorised to offer products and services under the CDR framework by accessing and using consumer data on behalf of an Accredited Data Recipient (ADR). This model enables businesses that are not directly accredited to participate in the CDR ecosystem, thereby accessing consumer data securely and offering services without the extensive regulatory requirements and operational overhead of full accreditation. The ADR in this arrangement is responsible for ensuring compliance with CDR regulations, overseeing data privacy and security.
This representative model plays an essential role in expanding the CDR's reach, particularly among small to medium enterprises, fintech startups, and niche service providers. By alleviating the cost and complexity associated with accreditation, the CDR Representative model encourages innovation and competition within the data economy, ultimately increasing the diversity of consumer-focused services.
Recent Statistics and Trends
To date, the Australian Competition and Consumer Commission (ACCC) has registered 195 CDR Representatives, with 59 new representatives added in the past year—a 20% decrease in registrations compared to the previous year. Concurrently, 30 representatives have been removed from the registry, reflecting the dynamic nature of this market segment.
The CDR Representative market has seen limited competition, with only two representatives transitioning between ADRs, indicating a low level of market fluidity. Additionally, two representatives—Greener Global and Waave—have progressed to achieve full ADR status, signaling that some businesses may use the representative model as a stepping stone to full accreditation.
Sectoral Insights: Fintechs and Energy Representatives
CDR Representatives primarily cater to fintech applications, leveraging the data-rich CDR framework to enhance financial service offerings such as lending, budgeting, and payment solutions. However, the energy sector is also seeing steady growth, with 23 energy-focused CDR Representatives now registered. This aligns with the CDR's phased expansion across industries and underscores the broadening scope of data applications in energy management and sustainability.
Active vs. Passive Representatives
While many CDR Representatives have developed proprietary software products, a notable portion relies on generic software solutions provided by their ADR partners. This suggests that some businesses view the CDR framework as an add-on to existing data collection methods, such as screen scraping, rather than fully investing in bespoke CDR solutions. This may reflect a wait-and-see approach by some companies, opting to offer CDR-enabled services without committing significant resources to custom technology.
Consumer Awareness and Engagement
One of the most significant barriers to the success of CDR Representatives is the general lack of consumer awareness of the CDR. Many consumers remain unfamiliar with the rights and benefits CDR offers, which limits their ability to fully leverage the services available. Unfortunately, CDR Representatives are not typically positioned to provide in-depth consumer education on the CDR itself. This responsibility largely falls to government and regulatory bodies, which could enhance outreach efforts to ensure consumers are informed and engaged.
The Registry allows consumers to search for CDR representatives now, and improvements at least allow consumers to view a description of the Software Product. However, this only benefits CDR Representatives with their own custom Software Product.
The CDR Representative model is a vital component of Australia’s data rights ecosystem. It broadens participation, reduces entry barriers, and fosters a more competitive and innovative data-sharing landscape. As the CDR expands and consumer awareness grows, the potential for representatives to deliver meaningful, data-driven services will likely increase, driving greater adoption and utility in the digital economy.
How AI is shaking up mortgage broking
In this podcast LMG group executive Customer Experience Jason Furnell talks about how AI, Open Banking and other tech tools will change the way brokers work, and explores the benefits and limitations of various technologies. Jason views Open Banking as part of a wider data-sharing environment that includes valuations, credit checks, and employment history. He does, however, highlight the value of statement data to the mortgage broker processes.
The Open Banking discussion starts at 32.20.
Podcast link: How AI is shaking up mortgage broking
Australia plans ‘reset’ of its Consumer Data Right regime
The Australian government has updated the Consumer Data Right (CDR) framework, further emphasizing its importance to the country's digital infrastructure. Originally introduced in 2020, CDR gives consumers control over their data, allowing them to share it with trusted parties for tailored services. Recent changes have expanded CDR from "data sharing" to "action initiation," enabling service providers to perform tasks on behalf of consumers, like making payments or switching accounts.
The Treasury Laws Amendment Act 2024 introduces roles for "accredited action initiators" (AAI) and "action service providers" (ASP) to manage these actions. To address high compliance costs, the government has also announced a "reset," proposing streamlined consent processes, a pause on telecommunications CDR implementation, and a move to phase out screen scraping. These measures aim to lower costs and boost CDR's adoption, with expansion planned for non-bank lending and "buy now, pay later" sectors by mid-2026.
Article link: Australia plans ‘reset’ of its Consumer Data Right regime