The CX Standards require that CDR participants MUST seek to have all aspects of the Consent Model comply with specifically referenced WCAG items.</p.

At a minimum, all CDR participants MUST seek to comply with those items throughout the Consent Model. These standards SHOULD be assessed, tested, and refined further by accessibility consultants directly involved in implementation.

The intention is for CDR participants to, at a minimum, comply with the specific WCAG items referenced in the CX Standards. However, we acknowledge that WCAG compliance may not be applicable to all aspects of the Consent Model, such as non-web experiences, and, as per WCAG conformance requirement 5, non-compliant technologies can still be part of the overall experience.

We would expect participants to be able to demonstrate that they have taken reasonable steps to achieve WCAG compliance, such as evidence that accessibility testing has occurred, and/or can note why compliance is not applicable for a particular experience.

The particular wording in the standards was chosen to provide a reasonable level of flexibility; to acknowledge that making the CDR accessible will be an ongoing process; and to recognise that WCAG items may not apply to all aspects of the Consent Model.

Section 3.2 of the CDR Rules (Joint account management services) provide details about revoking accounts owner by joint account holders. How should this process happen if an individual account owner wanted to revoke 1 of 2 accounts they are sharing with the ADR:

The answer provided below is in reference to the CX Guideline outlined on page 112 of the CX Guidelines: “Data holders SHOULD show the account(s) shared as part of the data sharing arrangement. It is at the discretion of data holders to provide functionality to add/remove additional accounts from the data sharing arrangement.”

Accounts are separate to consents. A consumer can choose to share data from some or all of their accounts in the authorisation flow, and - for ongoing data sharing arrangements - could later choose to remove some or all of those accounts.

Removing an account from a consent would stop data from that account being shared; it would not withdraw the consent. Similarly, a consumer could add accounts to an existing consent without altering the status of the consent itself.

The 'Edit accounts' function on Page 112 of the CX Guidelines is an example of how a data holder might choose to initiate this process. When the consumer selects ‘Edit accounts’, the expectation is that the consumer could then choose to add or remove accounts for that consent. Importantly, however, providing this functionality is at the discretion of data holders.

Can you please confirm that Voluntary and Required Product data referred to in the CDR Rules is NOT the same as the fields shown as Mandatory and Optional in the Data Standard?

i.e. all data items in the Data Standard are Required Product Data and Voluntary Product data refers to additional fields or APIs that Data Holders can decide to add if they wish.

Are all possible fees for a product to be included? There are many different sorts of fees, some of which are highly unlikely for the majority of consumers and could actually confuse them E.g.

Will there be any verification completed of the Product data provided by Data holders?

A Data holder could portray a more attractive product by not providing details of all possible fees. If all Data Holders are not interpreting this requirement in the same way then it could be detrimental to those adhering to these requirements.

Question on item 2.7 - We assume the reference to ‘CDR participants’ refers to other Data Holders and ADRs in the CDR eco-system. However, internal complaints handling systems and processes are developed to accommodate complaints received from customers of the bank. Is the expectation that DHs would extend existing complaints handling processes to parties other than customers? If so, This could potentially have a large impact to existing process

Will there be further clarity on how CDR participants are expected to deal with complains made by other CDR participants?

The API schema specification is not available for version 2 for Get Product and Get Product Detail (the schema within the responses section doesn't take you anywhere), however they are present in version 1 though. Links are below. Can we have them added in, to indicate the changes/the schema that was applicable for version 2.

Links-
Get Products v1 -
https://consumerdatastandardsaustralia.github.io/standards/includes/obsolete/get-products-v1.html#get-products-v1
Get Products v2 -
https://consumerdatastandardsaustralia.github.io/standards/includes/obsolete/get-products-v2.html#get-products-v2