Digital Identity NZ (DINZ), through its Policy and Regulatory Subcommittee, has provided feedback to the Ministry of Business, Innovation and Employment (MBIE) for the proposed open banking regulations and standards under the Customer and Product Data Bill. This collaborative submission reflects insights from DINZ members across New Zealand’s digital identity sector, representing both large and small organisations.

DINZ fully supports the Bill's goal to unlock the value of customer data, fostering competition and innovation. However, our submission highlights specific areas where the proposed rules could be enhanced to better achieve these objectives.

Empowering Customers through Open Banking

DINZ appreciates the Bill’s focus on giving customers control over their data, which can drive a more competitive and dynamic marketplace. However, we raised concerns around the prioritisation of the banking and electricity sectors, believing that a broader scope of competitive third-party providers is essential for success. Additionally, affordability is crucial, as the cost of third-party services could hinder widespread adoption.

Data Security and Privacy

Maintaining data security is a key focus for DINZ. While the Bill requires transparency from data holders and accredited requesters, we recommend aligning with the New Zealand Privacy Act 2020 to safeguard consumers' data without unnecessarily disclosing sensitive information. This ensures robust protection and trust.

Learning from Australia’s Open Banking Journey

Reflecting on Australia’s slow uptake of open banking, DINZ cautions against over-reliance on the Digital Identity Services Trust Framework (DISTF) as a singular solution. A more holistic approach is needed to address identity, verification, and consent challenges in the context of open banking.

Colin Wallis, Executive Director of Digital Identity NZ says: "DINZ supports the general direction indicated in the discussion paper, however it considers that not enough attention is being directed to the reasons behind the slow take-up in Australia. Additionally unintended consequences may arise from its seemingly over reliance on the DISTF as the magic bullet to resolve all the digital identity, verification, attribute exchange and consent - as much as we would all like that."

DINZ is committed to working with MBIE to ensure a secure, efficient, and inclusive open banking framework that benefits all Kiwis.

You can read the full submission here: https://digitalidentity.nz/wp-content/uploads/sites/25/2024/10/DINZ_Submission_on_CPD_Open_banking_designation_rules_10_Oct_2024_Final-Signed.pdf

About Digital Identity NZ

Digital Identity NZ (DINZ) is a not-for-profit, membership-funded association with around 100 organisations from both the public and private sectors. Representing diverse industries and individuals, DINZ is the leading voice for digital identity in Aotearoa. As part of the New Zealand Tech Group (NZTech), we connect the digital identity community and actively influence policy and solutions. Our members play a crucial role in advancing digital identity across various sectors—from public-facing government services to open banking, account opening, and customer and product data. These initiatives rely on digital identity, working alongside AI, biometrics, and cloud technologies.

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