Toronto, Ontario
(As prepared for delivery)
Introduction
Good afternoon, everyone.
Thank you for the warm welcome and thank you to the organizers of the Open Banking Expo for bringing us together at such an important moment for the future of financial services in Canada.
I would like to begin by acknowledging that the land on which we gather is the traditional territory of the Wendat, the Anishinaabeg, Haudenosaunee, Métis, and the Mississaugas of the Credit First Nation.
It is an honour to be here for what is my first speech as Acting Commissioner of Competition. Doubly so before an audience of innovators, builders, and disruptors who are challenging the status quo and reshaping how Canadians access financial services.
This year's Expo is taking place at a transformative time.
With the introduction of the Consumer-Driven Banking Act, Canada is moving towards the finish line in implementing Open Banking. This brings with it the promise of transforming everyday banking into something more secure, user-friendly, and empowering.
I can tell you that, at the Competition Bureau, we see this as a critical moment.
Top priority: affordability
When we prioritize our work at the Bureau, be it in enforcement or advocacy, we are focused on affordability for Canadians.
Every decision, recommendation, and enforcement action we take must ground itself in the simple reality that today, Canadians are feeling pressure from all sides. And Canadians deserve competitive markets-including financial markets-that work for them to provide more choice and flexibility.
For us at the Bureau, this means keeping our foot on the gas during this period of economic headwinds and structural change.
Because if affordability for Canadians is the destination, then competition-real, dynamic, innovation-driven competition-is the vehicle that gets us there.
And that is especially true in the financial sector.
A sector ready for disruption
Canada is rightly proud of our world-class banking system. Our regulatory frameworks have helped Canada weather trough storms better than most.
But we must not confuse stability with stasis. Over time, the same structures that helped protect us during crises have also served to reinforce market concentration and barriers to innovative products and services.
Today, Canada's five largest banks dominate the financial sector, accounting for most of the services provided to Canadians. There are significant barriers that make it difficult for new competitors to enter the sector.
There are barriers to switching as well, with a 2024 Abacus Data poll finding that two-thirds of Canadians had no intention of considering switching financial providers in the next two years.
In our view, disruption in this sector is not a luxury-it is a necessity. The sector needs new players to shake things up and create an environment where innovators can challenge incumbents, and where incumbents innovate and adapt. This would allow consumers to benefit from competition with lower prices, better service, and more choice.
Economist Joseph Schumpeter coined the concept creative destruction, where innovation drives growth as new technologies and firms out-compete the old. As we are seeing in the fintech space, this is not an abstract theory-it is something happening every day.
Innovators and disruptors create real value for consumers by:
Streamlining processes;
Lowering costs;
Increasing choice in products and services; and,
Pressuring incumbents to innovate or adapt.
And Canada needs more of this competitive vigour in a sector that is critical to all Canadians, and our economy.
However, simply saying the sector needs more competition does not make it so. It takes action by policymakers to ensure that our regulatory environment allows new entrants to bring this pressure on incumbents, to create the kind of rivalry that benefits consumers.
And as we have seen, consumers around the globe love the results of a Canadian heated rivalry.
And that's why open banking-and data portability more generally-is foundational. It doesn't just enable innovation - it puts in place the conditions for ongoing competitive pressure. It will empower consumers, lower barriers for new entrants, and drive the market to offer better products and services to Canadians.
But without an open banking framework, like what is proposed in the Consumer-Driven Banking Act, the value of open banking will remain limited.
The industry risks stagnating by missing the opportunity to evolve into a more dynamic, customer-driven marketplace. And access to data will continue to be gated by incumbents, with consumers remaining locked into relationships defined by friction rather than choice.
Our work on data portability
As Canada's competition watchdog, our role at the Bureau is to help ensure that innovators can challenge incumbents. We do this by enforcing the law and by advocating to Canadian policymakers for pro-competitive regulations across sectors.
We have a long record of work in the financial sector, reflecting its importance to Canadians and our economy.
On the enforcement side, there are many examples of our enforcement work over the years, under different regimes and legislation.
Our investigations bring scrutiny to business practices that may be restricting or harming competition. As they say, sunlight is the best disinfectant. An example of this is our recent investigation into Interac and e-transfers.
In 2024, following concerns raised by the House of Commons Standing Committee on Industry and Technology, we began looking into how Interac charges financial institutions to use the e-transfer system.
Interac was charging different prices based on volume of transactions. This benefited Canada's largest banks, who own and control Interac, and who process hundreds of millions of e-transfers each year. But it burdened smaller financial institutions with higher costs because they operate at a much lower volume.
Shortly after our investigation started, Interac announced that it was moving to a flat-fee model for e-transfers. This will help level the playing field. It will support more competition and innovation in Canada's financial services sector. This in turn will allow Canadians to benefit from greater choice, lower prices and better service.
Interac moved to this new pricing model in November 2025. We will continue monitoring to ensure that no additional barriers are put up.
This case is just one facet of our enforcement work in the sector, which includes our merger reviews.
I'll move now to our advocacy work in the sector.
Over the past decade, the Bureau has championed the adoption of open banking and data portability to encourage more competition in the financial sector, and others.
In 2017, after an extensive study, we published a report on technology-led innovation in the financial sector.
In that report, we recommended that "Policymakers […] embrace broader "open" access to systems and data through application programming interfaces.
And, since then, we have made a wide variety of submissions to consultations on the sector, highlighting the benefits of open banking and consumer-driven banking frameworks.
In 2022, we published the findings of our Digital Health Care Market Study. The report highlighted the potential benefits of unlocking the power of health data, and demonstrating the potential benefits of data portability to competition across sectors.
Our report
And that brings us to this year where, in January, we published the findings of our ground-breaking study on data portability. Using the insurance sector as a case study, our report makes the benefits of data portability concrete for consumers.
It puts a dollar value to the argument that we have long made-that the potential competition benefits from data portability are enormous.
The study found that introducing data portability in the insurance sector could save Canadians between $1.1 billion and $3.8 billion in annual costs. These savings come from switching to lower-priced insurance plans and from spending less time comparing providers and finding better offers.
However, these savings won't come simply by flipping the switch on data portability. Our report highlights some important challenges that will need to be overcome for Canadians to see the full benefits.
We found that most Canadians are not familiar with data portability, and have limited understanding of how it works or its benefits.
We also found that many Canadians have concerns about the privacy of their data in general, which can reduce their willingness to use data portability tools.
We also found that, today, Canadians face barriers to switching providers. These switching frictions limit the benefits of competition and make it harder for new entrants to enter the market and grow.
With these challenges in mind, our report identifies factors that will be critical for establishing a successful data portability framework in Canada.
First, strong privacy and security protections are essential. Canadians must be confident that their data is shared safely and securely. Without these protections, consumers will hesitate to use the data portability regime.
Second, clear consent rules are needed to ensure Canadians understand how and when their data is shared, so they know that they are in control of their personal information.
Third, high interoperability is important, so that systems can work together easily. It's not enough for consumers to be able to access their data. If data can't be easily transferred to another provider, consumers may still find it difficult to switch, limiting competition.
Fourth, compliance costs must be reasonable, particularly for smaller businesses, so participation and innovation aren't limited. For example, if the cost of building secure ways to share data and meeting ongoing requirements is too high, smaller firms may be unable to compete or bring new products to market.
Finally, effective collaboration between regulators, policymakers, and industry will be important to support the fair and successful implementation of a framework over time.
Taken together, these factors should form the basis of a future Canadian data portability framework. It is important that we get this right if consumers are to realize the potential benefits of greater choice, lower prices and more innovation.
What this means for open banking
I want to turn now to what these findings mean for open banking.
An effective open banking system will increase competition and support the creation and expansion of new and innovative firms.
It will reduce the barriers consumers face when switching providers, making it easier for people to choose the services that best meet their needs. This, in turn motivates businesses to offer better products, lower prices, and improved customer service to attract and keep customers.
Despite these benefits, many Canadians may hesitate to switch providers. We see a few major obstacles facing adoption:
- Concern that switching will be complicated or time-consuming;
- Loyalty to familiar brands; and,
- Lack of awareness of the real advantages of switching.
The right framework can help overcome these barriers by making it easier and safer to move data.
And we have seen in other jurisdictions that this works. The United Kingdom and the European Union have led the way, establishing robust data portability systems about a decade ago.
The United Kingdom's experience with open banking stands out as a mature example. Usership there is rising, with more than 12 million active users, more than 300 regulated firms, and an estimated contribution of £4 billion to the UK economy.
Their adoption of data portability in open banking has also disrupted traditional banking models, making it easier for consumers to switch providers and access new financial services.
For example, customers there are able to authorize third parties to make automatic payments on their behalf, providing new alternatives to standard payment methods.
Unfortunately, Canada has fallen behind its peers in this field. We cannot afford to fall further behind while other countries continue to move forward with the development of data-driven ecosystems.
However, we also have an important opportunity:
Rather than simply following in the footsteps of others, we have the advantage of learning from the successes and challenges faced by early adopters. By drawing these lessons, and avoiding the pitfalls experienced elsewhere, we can design a made-in-Canada data portability framework that not only catches up but leapfrogs ahead. There is potential to set a new global benchmark for competition and innovation.
We can get there with a framework that puts consumer empowerment and competition at its core. We can become a first mover jurisdiction in this respect.
Government momentum
And we are seeing meaningful progress from the Canadian government toward implementing open banking.
In Budget 2025, the government announced a commitment to advancing open banking by introducing legislation to complete the Consumer-Driven Banking Act, and by providing a data-mobility right in the Personal Information Protection and Electronic Documents Act. These are important steps toward facilitating data sharing across the economy.
In the budget, the government also recognized the importance of strengthening competition in essential services, including in the financial sector. They have also stated that competition will have an important role in the government's economic agenda.
The potential here is immense-but only if we seize this moment, act decisively, and place competition at the heart of our economic policy.
The role of industry
If Canada is going to build an open banking ecosystem, industry also has a critical role to play in ensuring its success.
Our research on data portability found that, for consumers, time and money savings are the strongest drivers of participation. This will be key for firms, as building services that offer real savings in time and money will be attractive for consumers.
When data portability allows for easier comparing and switching between providers, adoption increases significantly. If consumers aren't made aware of these benefits, or of the ease of switching, they won't take advantage.
In this, education is key - Canadians who understand how data portability works and how it could benefit them are 37% more likely to adopt it, while those who see it as very risky are 65% less likely to use it. To overcome this, industry will have to step up by designing user-friendly consent tools, investing in cybersecurity, and communicating clearly with consumers.
The core of this is that, if consumers don't feel confident sharing their data, adoption of data portability will be limited - and the competition benefits will be left unrealized.
Canadians need action from all of us-enforcers, regulators, policymakers, and innovators-to make open banking a reality.
The success of Open Banking will set the pace for future reforms.
If we get it right-if consumers trust and use the system-the lessons learned will guide the expansion of data portability into sectors like insurance, healthcare, energy, and beyond.
Turning back to what we can do at the Bureau, our work doesn't stop with this latest report.
We will continue to advocate for data portability and be active in the financial sector.
On the advocacy front, we are currently undertaking a market study of competition in the financing sector for small- and medium-sized enterprises in Canada. With this study, we plan to examine competitive dynamics and barriers to entry and switching in the sector.
We will also keep a close eye on the sector from an enforcement standpoint.
And on that note, when it comes to our work in the financial sector, I would be remiss if I didn't highlight how many in this room have been vocal about concerns with barriers to competition you face. We share these concerns, and your voices have helped disrupt the status quo.
You know best the barriers to entry and expansion that you're facing. Over the years, it is has been you telling us your insights and experiences that has helped us focus our work in the sector.
You know the problems you face better than anyone. My ask to you is to continue bringing your concerns forward about the barriers you are facing, be they regulatory or from other market participants, and put them on our radar.
Closing message: the economy Canadians deserve
As I conclude, I want to return to the priority that guides our work at the Bureau: making life more affordable for Canadians.
Competition lowers prices. It improves the quality of products and services. It creates more opportunities for innovators to launch and grow their firms. It ensures that businesses can challenge incumbents on a level playing field.
That's why I am so pleased to be speaking with you today. Many of the participants of this Expo are the current and future driving forces of Canada's financial sector, and will shape what this industry will be.
At the Bureau, we want to create an environment where Canada's fintech ecosystem thrives, where consumers are empowered, and where competition drives both innovation and affordability.
That's why we will continue advocating for competition and open banking in the sector. And we will also continue our work to be at the forefront of understanding emerging issues - such as stablecoins and AI agents - and their impact on competition in financial services.
The world isn't waiting to adopt open banking and data portability. And neither can we.
Let's move forward, and keep our foot on the gas in our efforts to make this a reality.
Thank you.
