CDR vendor dual-source — Basiq consumer, Frollo business
decisionactive
owner: philip · updated 2026-11-14
relates: aml-ctf-act-2006
CDR vendor dual-source — Basiq consumer, Frollo business
Context
- Basiq is the only CDR accredited data recipient with published pricing: $0.50/user/mo + platform fee (quote-only), 12-month minimum; covers 136 institutions (AU/NZ), claims 99% of population and all CDR data holders.
- Basiq CDR gaps are account-type gaps, not institution gaps: CommBank trust/deceased-estate accounts (resolution 15 Dec 2026), CommBiz trust profiles (31 Mar 2027), AMP Bank GO auth uplift — per the CDR rectification schedule (9 Nov 2026).
- Business/trust accounts require a nominated representative: the business appoints a representative via the bank's service, that person consents to share data. Frollo documents this flow at ANZ, Macquarie, and CommBank for trust accounts, business credit cards, retirement savings, and related account types.
- The CDR register has ~31 active accredited data recipients; the practical shortlist is Basiq, Frollo, Consentio, Fiskil, Adatree. None publish pricing cheaper than Basiq; Frollo, Consentio, Fiskil, Adatree are quote-only.
- Basiq offers three access methods: Open Banking (CDR, primary), Web Connector/DDC (credential-based screen scraping, in decline as banks tighten bot protection), and Statements Upload (PDF/CSV, point-in-time fallback).
- Quiltt is excluded: US/global open-banking API (MX, Finicity, Akoya partners), no ACCC accreditation, no AU CDR coverage.
- Incumbent AML vendors do not productize the business-account authority chain (entity KYB → nominated representative → representative KYC → CDR consent).
Decision
- Use Basiq as the primary CDR source for consumer accounts ($0.50/user/mo + platform fee; free sandbox via Developer Dashboard, test bank "Hooli").
- Source business/trust account coverage from Frollo (or the best quote among Frollo, Consentio, Fiskil, Adatree covering trust accounts) — dual-source by account type.
- Productize the authority chain as a guided business onboarding flow: KYB (Didit/First AML) → nominated-representative instructions per bank → representative KYC (Didit/DVS) → CDR consent. This is the differentiator; no incumbent ships it.
- Use Basiq Statements Upload as the fallback for banks/accounts not yet on CDR; treat DDC as a transition-only path, never the default.
Consequences
- Two CDR integrations to maintain (Basiq + Frollo) with different consent and data models; mitigated by normalizing transactions into one internal typology/monitoring layer.
- Frollo (or alternative) pricing unknown until quote; consumer-vs-business cost split must be modelled before committing to per-end-customer pricing.
- Nominated-representative nomination is one-time per business but bank-specific; the guided flow must carry per-bank instruction content (KB
copy/context entries). - Consumer CDR coverage is strong today; business/trust coverage improves as CDR rectification dates land (CommBank trust Dec 2026–Mar 2027) — revisit single-source consolidation at scale.
- Sandbox access is immediate for Basiq (500-connection limit, free for testing); Frollo sandbox terms unverified.
Sources
- https://api.basiq.io/docs/access-method
- https://api.basiq.io/docs/frequently-asked-questions
- https://www.basiq.io/resources/supported-insitutions.html
- https://help.frollo.com.au/hc/en-au/articles/13411949336719-How-to-enable-non-individual-and-business-accounts-in-CDR
- https://www.cdr.gov.au/for-providers/rectification-schedules/rectification-schedule-active-data-holders-gaps
- https://www.cdr.gov.au/find-a-provider
- https://blog.fiskil.com/best-api-cdr-compliant-bank-data-access-review-850593c0
- https://faun.dev/toolbox/basiq-vs-frollo/