Reciprocal data holder obligations

An accredited person may be subject to reciprocal data holder obligations. This means that an accredited person may be required to share particular CDR data at particular times in accordance with the obligations of a data holder under the CDR Rules, separate to the obligations of an accredited person.

Reciprocity under the CDR Rules applies in respect of CDR data that is:

• generated and held by or on behalf of an accredited person; and
• where the data is generated in respect of a product that is publicly offered by the accredited person to consumers and generally known as one of the types of products in Phase 1, Phase 2 or Phase 3 products.

For example, a non-bank lender that is accredited may become a reciprocal data holder in respect of data they generate for their personal loan products. A non-bank accredited person that provides a budgeting app, but does not offer any of the banking like products listed in Phase 1, Phase 2 or Phase 3, will not be a reciprocal data holder.

A phasing table summarising mandatory data sharing obligations for reciprocal data holders is available on the CDR website.

We encourage applicants with questions or wanting to discuss how these obligations may apply to them, including possible exemptions, to submit an enquiry via the CDR Support Portal.