The Open Banking Dilemma: Structural Reform or Oligopoly Reinforcement?

This case examines the policy dilemma facing Canadian regulators as they finalize the implementation framework for consumer-directed banking, commonly referred to as open banking. While Parliament has passed legislation and the government has initiated development, key decisions remain unresolved. The case situates this decision within the context of Canada’s highly concentrated banking sector, where just six banks control the majority of financial assets.

Putting students at the helm, from the perspective of a senior official at the Department of Finance responsible for implementation, the case explores the choices regulators have to make about timing, security rules and participation. These choices will determine whether Canada has meaningful banking competition or if the result is merely a modernization of existing banking oligopolies.