Essential CDR FAQs for Non-Bank Lenders in July 2025

Mike Booth
Jun 9
8 min read

As the Consumer Data Right (CDR) continues to expand across the Australian economy, non-bank lenders are now firmly in scope. With the first compliance date set to 13th July 2026, now is the time to have a safe delivery plan.

This FAQ provides clear, concise answers to the most common questions non-bank lenders have about their CDR obligations. This is a complex area, so please consider this general information. Contact your compliance lead or connect if you would like to understand your specific obligations.

What is the Consumer Data Right (CDR)?

The CDR gives consumers greater control over their data, allowing them to securely share it with accredited third parties. It aims to increase competition and innovation across sectors, starting with banking and now extending to non-bank lending.

Are non-bank lenders (NBLs) required to comply with CDR?

Yes, if you have over $1bn in resident loans and finance leases and over 1000 customers. You can find more details on specific criteria and the implementation timing here.

How do I know if my lending products are in scope for CDR?

A lending product is in scope if it meets the definition of a “non-bank lending product” under the CDR rules. There are three key factors to consider:

Is the product listed in clause 1.4 of Schedule 3 of the CDR Rules?
Is the product publicly offered?
Is the product offered by way of a standard form contract?

The Covered CDR NBL products are:

(a) a personal credit or charge card account;

(b) a business credit or charge card account;

(d) a home loan for an investment property;

(e) a mortgage offset account;

(f) a personal loan;

(g) business finance;

(h) a loan for an investment;

(i) a line of credit (personal);

(j) a line of credit (business);

(k) an overdraft (personal);

(l) an overdraft (business);

(m) asset finance (including standard vehicle financing and leases); voluntary for non-standard vehicle finance such as notated leases and fleet finance;

(n) a consumer lease (voluntary);

(o) a reverse mortgage (voluntary);

(p) a buy now, pay later product.

What about my NBL-specific product?

Each non bank lender has specific products and features. However recent guidance on common NBL products is now available. Here's a summary:

Covered Products:

Product	Description	Is it a Covered Product?
Business loan	A loan product that can only be used for business purposes. The loan can be of a fixed balance or one that reduces over time. It can be a secured or unsecured loan.	Yes: this type of business loan is a publicly offered product in the banking and NBL sectors that should be made available for product data and consumer data sharing by the bank or NBL.
Business line of credit	Line of credit that can be drawn on by a business if and when needed for a specified term. This line of credit may be secured or unsecured	Yes: this type of line of credit for business purposes is a publicly offered product in the banking and NBL sectors that should be made available for product data and consumer data sharing by the bank or NBL.
Equipment loan (also known as a chattel mortgage or a goods loan)	A loan that allows a business to borrow money to purchase an asset. The lender has the asset as security until the business’ repayments are completed.	Yes: this equipment loan is a publicly offered product in the banking and NBL sectors that should be made available for product data and consumer data sharing by the bank or NBL.
Inventory finance 2 (low level of negotiation)	A facility that allows the business to pay its supplier to fulfil a purchase order prior to invoicing its customers.	Yes: this product is a banking and NBL sector product. While it is only offered to large institutional banking clients, it is subject to low levels of negotiation and is therefore likely considered to be publicly offered.
Online buy now pay later service offered before 13 July 2026	A service that enables consumers to purchase goods and services by paying part of the purchase price at the time of the transaction and the remainder to the buy now pay later provider in a series of instalments.	Yes: this is a banking and NBL sector product that is publicly offered and likely to be covered for product data (after 13 July 2026) and consumer data sharing (9 November 2026).
Buy now pay later service offered in-store through QR code scan after 13 July 2026	A service that enables consumers to purchase goods and services by paying part of the purchase price at the time of the transaction and the remainder to the buy now pay later provider in a series of instalments.	Yes: this is a banking and NBL sector product that is publicly offered and likely to be covered for product data (12 months after the date that the data holder first offered a BNPL product – ‘BNPL date’) and consumer data sharing (15 months after BNPL date).
Foreign currency transaction account	Transaction account that allows customer to make and receive payments in a range of different foreign currencies.	Yes but voluntary: this type of foreign currency account is a publicly offered banking product, however, data sharing for this type of product is voluntary as it falls within the list in clause 3.2(3) of Schedule 3.
Reverse mortgage	A financial product that allows a borrower to use the equity in their home as a guarantee for a loan.	Yes but voluntary: this type of banking and NBL sector product is likely to be considered a ‘publicly offered’ product, however, data sharing for this type of product is voluntary as it falls in one of the categories listed in clause 3.2(3) of Schedule 3.
Margin loan	Loan which enables a customer to borrow funds to invest in the share market. The margin loan is secured against the customer’s existing shares or managed funds.	Yes, but voluntary: this type of margin loan is a publicly offered product in the banking and NBL sectors, however, data sharing is voluntary for this product as it falls within the list in clause 3.2(3) of Schedule 3.

Not Covered Products:

Product	Description	Is it a Covered Product?
Invoice finance	A facility that advances funds against unpaid invoices prior to the business customer/s making payments.	No: this type of invoice finance product is unlikely to be considered a ‘publicly offered’ product, and therefore is unlikely to be a CDR covered product.
Inventory finance 1 (high level of negotiation)	A facility that allows the business to pay its supplier to fulfil a purchase order prior to invoicing its customers.	No: this type of inventory finance product is unlikely to be considered a ‘publicly offered’ product, and therefore is unlikely to be considered a CDR covered product.
Structured investment product with a loan component	Capital guaranteed investment product that includes a loan component to businesses. Product involves a combination of a bank deposit with an option or a leveraged investment in the underlying asset.	No: this type of structured investment product is unlikely to be considered a ‘publicly offered’ product, and therefore is unlikely to be a CDR covered product.
Multi-option credit facility	Credit facility which allows the customer to utilise multiple products within the overall credit facility. The credit facility has an overall limit and the credit products that are linked to the credit facility are able to be used to drawn down from that umbrella limit.	No: this type of credit facility is unlikely to be considered a ‘publicly offered’ product, and therefore is unlikely to be a CDR covered product.
Trade finance	A financial instrument or product that is used by businesses to facilitate trade (importing and/or exporting goods or services).	No: we do not consider this type of product to be a banking or NBL sector product for the purposes of the CDR Rules.
Trade payable finance	An uncommitted revolving trade finance facility available to a buyer of goods and services where the bank finances the buyer's payments to approved suppliers before the invoice due date.	No: we do not consider this type of product to be a banking or NBL sector product for the purposes of the CDR Rules. Additionally, this product is unlikely to be considered ‘publicly offered’.
Trade receivable finance	Short-term finance to sellers of goods and services whereby the bank purchases individual eligible trade receivables.	No: we do not consider this type of product to be a banking or NBL sector product for the purposes of the CDR Rules. Additionally, this product is unlikely to be considered ‘publicly offered’.
Corporate and structured finance	Covers a range of complex financial solutions and is typically provided to large banking clients in a highly tailored manner.	No: we do not consider this type of product to be a banking or NBL sector product for the purposes of the CDR Rules. Additionally, this product is unlikely to be considered ‘publicly offered’.
Financial markets products	Products traded via regulated financial markets	No: not considerer a type of product to be a banking or NBL sector product for the purposes of the CDR Rules.
Bank guarantees or undertakings	Commitments by the bank on behalf of a customer to pay a specified amount to a third party	No: not considered a type of product to be a banking or NBL sector product for the purposes of the CDR Rules.
Foreign currency transaction account – Trial product for 5 months to less than 1000 customers	Transaction account that allows customer to make and receive payments in a range of different foreign currencies	Trial product: this type of account is a banking product which satisfies the factors in clause 1.5 of Schedule 3. Data holders are not required to comply with CDR obligations in relation to a covered product while it is a trial product. A covered product in the banking and NBL sectors is a trial product if it is: for the purposes of the trial, supplied to 1000 customers or less, offered with the description ‘pilot’ or ‘trial’, and offered with a statement specifying: a trial period of 6 months or less, and the product may be terminated before the end of the trial period, in which case CDR data in relation to the product may not be available for data sharing under the CDR rules.

What if I only offer commercial lending products?

If your products are exclusively for large businesses or do not meet the definition of a “non-bank lending product,” you may not be in scope. However, you should assess each product individually.

What do I do if I don't meet the threshold or offer covered products?

Data holders may also apply for an exemption in relation to data sharing or other CDR obligations. For more information about how to apply for an exemption please see the ACCC’s Guidance for Applicants Seeking Exemption under Section 56GD.

What are "complex requests" and do I need to consider them?

A ‘complex request’ is a consumer data request that:

is made on behalf of a secondary user (person nominated to authorise data sharing by the account holder)
relates to a joint account (account with two or more account holders) or a partnership account (non-individuals), or
is made on behalf of a CDR consumer who has a nominated representative (individual nominated by the non-individual or partnership to act on behalf of the non-individual or partnership).

NBL initial and large providers will not be required to respond to complex requests at this time, but it may become an obligation in the future.

What are the penalties for non-compliance?

Breaches of most CDR safeguards can lead to civil penalties capped at the greater of $500,000 for individuals or $10,000,000 for corporations, three times the value of the benefits obtained, or 10% of the entity's annual domestic turnover.

Want to know more?

I have worked extensively with regulators, banks, energy companies, and data recipients to successfully comply, deliver, run, and operate their CDR capabilities.

If you want to reduce the cost to comply, or identify areas to compete using CDR, contact us to find out more about our solutions and accelerators.

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