Consumer Data Right: Trusted Advisers

Content Summary

From February 2022, the accounting data you access on behalf of your clients may be captured under the Consumer Data Right (CDR) in banking. If this happens, your client will need to nominate you as their Trusted Adviser to be the holder of that accounting data. 

Who is a Trusted Adviser in the CDR in banking?

Trusted Advisers are prescribed under CDR Rule 1.10C. They include:

  • qualified accountants within the meaning of the Corporations Act 2001
  • registered tax agents, BAS agents and tax (financial) advisers within the meaning of the Tax Agent Services Act 2009
  • relevant providers (financial services licensee, their authorised representatives, employees and directors) within the meaning of the Corporations Act 2001.

For the full list of Trusted Advisers, please refer to the legislation.

Who are the key participants? 

  • Consumer: the owner of the data, your clients.
  • Data holder: in banking, an Authorised Deposit-taking Institution (ADI), commonly referred to as banks. Over time this will expand from ADI banking to incorporate new industry sectors and include parties such as energy and telecommunication providers.
  • Accredited data recipients (ADRs): a receiver of data direct from data holders, such as an online accounting software provider. Any person or organisation may become an ADR if they meet the rigorous privacy and data security requirements under the CDR rules. Check who is accredited here.
  • Trusted Adviser: a person or organisation that belongs to one of the classes as prescribed in the CDR rules.

Possible impacts

Various participants under the CDR may ask you to confirm that you are from a class of Trusted Adviser. This may take the form of a contractual warranty, an attestation or representation by the Trusted Adviser. We will continue to work with all participants under the CDR rules as the standards for Trusted Advisers are finalised to ensure there will be minimal disruption to the relationship between consumers and their Trusted Advisers.

The new language

Using the example of an online accounting software platform that has become accredited in the CDR regime, here are some translations from the language we’re familiar with to CDR terminology:

  • Bank – data holder
  • Online accounting software provider – accredited data recipient
  • User/client – consumer
  • Accountant, tax or BAS agent, financial adviser – Trusted Adviser


Additional steps

To ensure the integrity of the CDR rules, you’ll need to follow some extra steps after a client nominates you as their Trusted Adviser. Those steps may include:

Find out more:

Additional information, news and resources can be found here, including:


CPA Australia continues to work in collaboration with Chartered Accountants Australia New Zealand, the Institute of Public Accountants and the Institute of Certified Bookkeepers in the application of CDR to our sector – specifically how it applies to our members.