Date posted: 24/05/2022

Joint submission to the statutory review of the consumer data right

The joint accounting bodies are concerned that the CDR legislative framework undermines consumers’ control of their data and inhibits innovation.

The professional accounting bodies’ review of the consumer data right (CDR) legislative framework found it becomes more complex as each industry sector is designated. This complexity undermines the intent of the CDR, to empower a consumer to control and use their data to their benefit.

Our findings raised concerns with the first stage in expanding the CDR across the economy, the assessment of a sector for designation. To date, these appear to be based on assumptions rather than statistical data to determine the likely impact on participants and if designation would be in the public interest.

Once designated, a new sector creates a need for more rules, which in turn creates a need for more standards. For operators captured in the sector first designated, the banking sector, each subsequent designation triggers more investment in software and processes to accommodate that sector’s specific rules and standards.

This flows through to our members who, to service their clients, require access to complete accounting data drawn from all sectors a client utilizes such as banking, energy, telecommunications and, potentially, non-bank finance. Our members will find it necessary to invest in software and establish processes to receive data through CDR channels while maintaining current systems to receive and analyse data through existing channels.

We again called for the expansion of the CDR to be placed on hold and Treasury resources directed to analysing the current use of CDR channels to identify and address fatal flaws.

We thank the members of the professional accounting bodies for their contribution to this submission.

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