CX Guidelines | Changes stemming from CD376 (White label brand arrangements)

[BikramKhadka-DSB]

Description

As part of Consultation Draft 376, the DSB has proposed a set of CX guidelines to support the introduction of white label brand arrangement standards. These CX guidelines aim to ensure better consumer experience in scenarios where white label brand arrangements exist for data holders.

Intention and Value of Change

The DSB publishes CX guidelines to assist participants with implementation of the CDR. The publication of draft CX Guidelines will allow the community to provide feedback on proposed changes and seek further clarifications where necessary.

N.B. These wireframes should not be taken as definitive guidance of compliance with the standards and should not be considered as legal or compliance references for the purposes of implementation.

Relevant participants

These CX Guideline changes are relevant to data recipients, data holders, technical integrator and solution providers in the banking, energy and non-bank lenders sectors. These guidelines will demonstrate how white label brand arrangements can be implemented in the CDR consent model.

Area affected

Based on CD376, changes are expected to have minor impacts to the CX Guidelines for:

• Collection and use consent: Default example
• Authenticate: Redirect to App
• Authenticate: Redirect to One Time Password
• Authorise to disclose
• Amending authorisations

New item or change proposed

Draft guidelines for consultation include:

• Collection and use consent: Default example
  • Proposed update to CX Guideline 31
• [NEW] Collection and use consent: Provider selection for white labeled brands
  • Proposed new variant for Collection and use consents, with focus on the data holder selection screen.
• Authenticate: Redirect to App
  • New CX Guideline 37
• Authenticate: Redirect to Web with One Time Password
  • New CX Guideline 17
• Authorise to disclose
  • New CX Guideline 30
• Amending authorisations
  • New CX Guideline 29

Feedback

The DSB invites community feedback on these artefacts and any other CX guidelines seen as necessary to support the changes stemming from CD376.

Feedback can be submitted via this GitHub thread as comments or emailed to contact@dsb.gov.au.

Noting the Christmas and New Year holiday period, feedback on this consultation is requested by 30 January 2026.

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⚠️ Disclaimer ⚠️
The CX Guidelines provide optional implementation examples for key rules, standards, and best practice recommendations.

They demonstrate key aspects of the consent model, but certain areas may be considered out of scope. This may include, for example, where the rules and/or standards are silent or non-prescriptive to provide CDR participants with flexibility or discretion according to their own systems or protocols.

❗The CX Guidelines span policy, rules, standards, and best practice, so requests will be considered on a case by case basis and timings may not fall within a Maintenance Iteration cycle.

Importantly, the CX Guidelines are optional to follow, but the CDR rules require CDR participants to have regard to them. The CX Standards differ in that they are binding data standards that must be followed.

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• Edited 18.12.2025 to add consultation feedback deadline

[markskript]

Hi @BikramKhadka-DSB

On the page "1CO: 06" of the "CR715" Figma, there is guideline 4, which states that "Data recipients should review the brandName field to ensure that provider names and logos are unique and consistent with their existing non-CDR presentations".

It then states that "If the brandName field is not unique or easily recognisable, data recipients should adjust how this information appears".

It's my opinion that neither of these are workable guidelines. There is no programmatic way an ADR could review the brandName field for "consistency with non-CDR presentations", or programmatically determine if the brandName is "easily recognisable" to the consumer.

I also don't think the DH's would support an ADR renaming their brands on the DH selection screen away from what is in the register.

Let me know if I've misinterpreted this. Thanks!

[BikramKhadka-DSB]

Hi @markskript,

Thanks for taking the time to provide your feedback.

The intent of this guideline is to support consumer comprehension when selecting a data holder, particularly to reduce the risk of consumers selecting the wrong provider and subsequently dropping off. It is not intended to introduce a new requirement, programmatic or otherwise, for ADRs to assess brand recognition. Rather, it reflects a consumer oriented guideline based on observed practices, where some ADRs already seek to align the presentation of data holders in their CDR flows with how those providers are presented in their non-CDR experiences, where separate consent flows exist.

We acknowledge your point that concepts such as “consistency” and “recognisability” are subjective and not readily determinable in a technical or automated way. We will take this feedback on board, alongside any further input from other participants, as we continue internal discussions and consider how best to clarify the intent and application of this guideline.

[CX-DSB]

Hi everyone, The feedback period for these guidelines has now closed. We’ll review all submitted feedback and post an update here once the new CX guidelines are published.