Open Banking Should Make You Recalculate Your Marketing Staples
Phase one of Canada's Consumer-Driven Banking Act (sometimes called “open banking”) goes into effect early this year.
In a nutshell, open banking is about giving consumers total control of their financial information. It’s a big technology story with fancy terms like FAPI, mTLS and screen scraping (sounds gross, kinda is).
This might seem like something just banks and fintechs need to worry about. They’re certainly the most affected, to be sure. The act ends registered account transfer fees, it makes it dead simple to switch banks, and you’ll look back in horror at how much paperwork there was just to shop a rate around by this time next year.
But we don’t think it is confined to just the operational ins-and-outs of banking. In fact, we think there’s a story here for any organization that deals with money, which is to say all of them.
The power shift
Open banking looks a lot like other platform shifts we've seen. When data becomes portable, and switching becomes frictionless, power shifts from whoever holds the data to whoever creates the most value with it.
Music didn't stay locked to CDs. Photos didn't stay locked to cameras. Your contacts didn't stay locked to one phone. Every time this happens, the same thing occurs: the companies that controlled distribution lose leverage, and the companies that built the best experience win.
Imagine a non-profit organization trying to figure out the best default donation to suggest to a donor. Today, you could approach this by reviewing averages (good) or by profiling the person based on their online behaviour (better). But with a working open banking framework in place, you could tailor it to their financial behaviour (best). Of course, you need to be really trustworthy to convince someone to turn over that kind of information.
And this is where the non-technical consequences of open banking show up. These new capabilities bring into question old marketing die-hards:
Loyalty becomes transactional (literally). Seriously evaluate the places you and your customers interact today. Spare no touchpoint because these interactions will be a chance to lose or keep them. And this isn’t just about the ease of switching. As consumers get accustomed to the convenience that comes with platform shifts like this, they expect you to know them and act in their best interest.
Bundling goes from comfortable to confining. When it’s easy to use the best from anywhere, customers will see bundles as traps that make them spend needlessly. Instead, focus on orchestration – make the connections for the customer, even if those connections aren’t from your organization. There is always value in being the partner who made things easier.
Retention performance trumps acquisition cost. When switching was hard, getting customers in the door mattered most. Now onboarding is frictionless for everyone. The metric that matters is how consistently you prove you're worth staying with, not how cheaply you acquired them.
There’s Time To Think About This
That’s by no means an exhaustive list. There are all sorts of questions about brand (“open banking” itself suffers from a branding problem, frankly), messaging, cross-selling and plenty of other marketing staples. Luckily, open banking doesn’t go into full effect until 2027. The phase we’re entering in 2026 is “read only,” meaning actually performing transactions (phase 2) is more than a year away.
As we said, this may be, first and foremost, a finance-sector initiative, but finance permeates every business, organization, and citizen in Canada. Making the most of the new capabilities will be one more way to win for retailers, non-profits, attractions and even us here in agencyland as we figure out how this might play into ad targeting and purchase funnels.
If you’d like to think about this with us, reach out!