Consent-First Onboarding for Consumer-Driven Banking: A Phase 1 Playbook for Canada

4 min read | Open Banking · Consumer-Driven Banking · Real-Time Rail (RTR) · Compliance

Ask a product leader how their onboarding flow pulls in banking data, and the honest answer often involves a login screen that isn't theirs. Roughly nine million Canadians share financial data by giving their banking credentials to third-party apps, a practice called screen scraping. Nobody loves it. It has simply been the only option available.

That's changing. The Consumer-Driven Banking Act is now law, the federal government published draft regulations this summer, and open banking in Canada is finally moving from policy to practice. Phase 1 brings read-only data sharing through secure, accredited connections. Phase 2, which adds write access such as payment initiation, is tied to the maturity of the Real-Time Rail.

Most of what's been written so far explains what the framework is. We want to look at something more practical: how to design onboarding around open banking consent so the work you do for Phase 1 still holds up when Phase 2 arrives. Here's where we'd focus leadership attention.

What Phase 1 Unlocks for Your Business

First, it's worth being clear on what Phase 1 actually makes possible, and why it deserves attention long before any payment features show up.

The first phase is all about reading data. Under Canada's consumer-driven banking framework, an accredited provider can see details like balances and transaction history through secure APIs, with the customer's express consent, instead of logging in as the customer. Even this will arrive in stages: deposit and payment accounts come first, then lending and investment accounts. For most businesses, that makes it the right starting point for income verification, account ownership checks, cash flow-based underwriting and smoother onboarding. These are the moments when a customer decides whether to trust you with their financial life.

What comes after that is write access, which brings payment initiation. Accredited providers will be able to move money and manage products on a customer's behalf, but only once the Real-Time Rail (RTR) is live and widely used. Payments Canada is targeting an RTR launch with initial participants in Q4 2026, and there's no firm date for write access yet. So, for now, the real work is in Phase 1.

This is why Phase 1 deserves executive attention. Whatever consent experience you build now becomes the base layer for everything that follows. Build it narrowly and you'll probably end up rebuilding it. Build it with clear scopes, durations and records, and adding new permissions later becomes a straightforward extension. Phase 1 is where customers decide whether to trust you with their data.

Why Consent Has Become a Leadership Issue

It's tempting to hand consent to the legal team and move on. The draft regulations make that risky, because they turn consent into an operational process with real accountability attached.

Under the proposed rules, customers must give express consent with clear disclosures about purpose, scope and duration. Consent lasts up to 12 months and needs renewing sooner if login details are compromised or circumstances change significantly. On the first data request in each consent period, the customer confirms with their own bank using multi-factor authentication. Consumers generally aren't liable for losses unless they were grossly negligent, so that risk sits with participating businesses, and penalties can reach $10 million per violation.

There's a real commercial upside too. The federal government estimates the framework will deliver about $13.2 billion in benefits over ten years against roughly $457.7 million in costs. Canadians are still cautious, though: 63% name data security as a main concern about open banking. That's why consent matters so much. It's where regulatory risk and customer trust meet, and the companies that handle it well are the ones customers will feel comfortable connecting their accounts to.

Designing Consent Customers Actually Understand

This is where consent UX comes in. It's the part of Phase 1 your customers actually see, and the screens, wording and flow decide whether they finish onboarding or drop off halfway.

The regulations set out the steps, but the experience your customers see is still largely yours to design. A few habits tend to make the biggest difference:

• Lead with the purpose, in plain words. “We'll review 12 months of deposits to confirm your income” is far clearer than “Grant access to account data.”
• Ask only for what the use case needs, and let customers choose which accounts to share.
• Match the duration to the job. A one-time income check doesn't need a 12-month consent, and the end date should always be visible.
• Prepare customers for the hand-off to their bank, so the redirect feels expected rather than suspicious.
• Give revocation of the same UX care as sign-up. A simple view of connected accounts and a one-tap way to disconnect shows customers they're in control.
  

Here's how that might look for a lender serving small businesses. At onboarding, it asks for read access to the applicant's business account for one clearly labelled reason: reviewing 12 months of cash flow to make a credit decision. If the business is approved, the lender asks separately for ongoing access to monitor balances, with the renewal date shown up front. The customer always knows what they agreed to and why.

Data Minimization and Auditability: The Quiet Advantage

Good consent design gets customers to connect. How you handle their data afterwards is what keeps regulators, partners and customers comfortable for the long haul.

Minimization comes down to one question for every field you collect: do we actually need this for the purpose the customer agreed to? When consent is withdrawn or not renewed, participants must delete the affected data on request or de-identify it. That's much easier if you never collected more than you needed.

Then there's auditability. The draft regulations require participants to keep compliance records for five years, report annually to the Bank of Canada on consents and deletion requests, and check a counterparty's accreditation on the Bank's public registry before sharing data. If something goes wrong, those records show where it happened and who's responsible. A good starting point for what to capture:

Moving Off Screen Scraping Without Disrupting Customers

For many businesses, the hardest part of Phase 1 isn't building something new. It's retiring something old that still works well enough.

The Consumer-Driven Banking Act contemplates a ban on screen scraping, but it isn't in force yet and the timing is still under consultation. That buys businesses some time, though it won't last forever, and the two approaches are very different:

Most transitions start with an inventory of every flow that relies on credentials, ranked by customer volume and risk. From there, many teams move new customers to the consent-based flow first, then invite existing customers to reconnect. It's also worth thinking about accreditation early, since the draft regulations offer a streamlined pathway for payment service providers already registered under the Retail Payment Activities Act.

Bringing Consented Data and Payments Together

Ultimately, consented data is most valuable when it leads somewhere, and in payments, that usually means moving money. As we noted in our mid-year review of the payments trends shaping 2026, open banking is shifting from policy to practice, and this is where your Phase 1 plans and your payments strategy should start to converge.

Even before write access arrives, read access can make payment experiences noticeably better. Picture a property management platform that confirms a new tenant's account ownership and income in minutes, then sets up recurring rent collection by EFT. Or a lender that verifies cash flow through consented data, then disburses approved funds in near real time through Visa Direct® or Mastercard® Send. Better data at onboarding means fewer failed payments and less manual review.

This is the kind of flow DCPayments' Canadian payment platform and API stack was built for. One partner gives businesses access to Interac e-Transfer®, EFT, Visa Direct, Mastercard® Send, virtual wallets and card processing, and our sandbox lets product teams test everything before going live. As write access takes shape, the consent foundation you build today means you can add payment initiation without starting over.

Where Does This Leave Canadian Fintechs?

Phase 1 of open banking in Canada is a rehearsal for what comes next. Businesses that treat consent as part of the product, rather than a compliance form, will be ready to move when payment initiation arrives. If you're considering this, these three questions are a good place to start:

1. Where do we still rely on customer banking credentials, and what would it take to move those flows to consent-based access?
2. Is our consent design built to stretch from read access to payment initiation, or will we need to rebuild it?
3. Could we prove today exactly what each customer agreed to, and what we did with their data?

Want a second set of eyes on your consent design? Get in touch with DCPayments, we'd be glad to talk through your onboarding flows, look at where consented data and payments can work together, and help you plan a path from Phase 1 to payment initiation.

Frequently Asked Questions

What does Phase 1 of open banking in Canada enable?

Phase 1 lets accredited providers read a customer's financial data, such as balances and transaction history, through secure APIs with the customer's express consent. It supports income verification, account ownership checks and cash flow-based underwriting, without customers sharing their banking passwords.

How should consent and revocation work under consumer-driven banking?

Under the draft regulations, customers give express consent with clear disclosures about purpose, scope and duration. Consent lasts up to 12 months, and customers can withdraw it at any time, after which their data must be deleted on request or de-identified.

How does the Real-Time Rail affect write access?

Write access, including payment initiation, depends on the Real-Time Rail being live and widely used. Payments Canada is targeting an initial RTR launch in Q4 2026, and no firm date has been set for write access itself.

Is screen scraping banned in Canada?

Not yet. The Consumer-Driven Banking Act contemplates prohibition, but it hasn't been brought into force and its timing is still under consultation. Businesses that rely on screen scraping should plan their move to consent-based API access now.

Further Reading

• The Way We Pay: A Mid-Year Review of the Payments Trends Shaping 2026 (https://dc-payments.ca/resource-hub/the-way-we-pay-a-mid-year-review-of-the-payments-trends-shaping-2026)
• The Future of Payments in Canada: Inside the Launch of the Real-Time Rail (https://dc-payments.ca/resource-hub/the-future-of-payments-in-canada-inside-the-launch-of-the-real-time-rail)