The simplest way for NBLs to meet the CDR 13 July compliance obligation
For non-bank lenders (NBLs), CDR Tranche 1 compliance is no longer a future problem — it’s a hard deadline. If you are a non-bank lender with a loan...
Which CDR Solution is Right for Non-Bank Lenders?
We have put together a CDR solution comparison to help customers make an informed decision about a real and imminent problem for non-bank lenders required to comply with the CDR. It is a balanced view of the options available to achieve compliance for Tranche 1 (product data) ahead of the July 13 deadline.
We have not included the option to build your own solution, as if you don't currently have a build plan in place to meet the deadline, your only likely option will be to buy one.
The quick answer
If your goal is PRD compliance by July 2026:
Biza Product Manager is the lower-risk, faster path. Built specifically for the CDR, with NBL multi-brand handling, API PRD management, and bulk rate update out of the box.
If you also need Design and Distribution Obligations (DDO) compliance and product governance:
ProductCloud offers something Biza does not — a single platform covering CDR, DDO, and internal product workflows. Worth evaluating if DDO is a live gap right now.
If you want a single CDR provider for both Holder and Recipient obligations:
Biza’s Holder as a Service (HaaS) solution meets your Holder requirements (PRD and consumer data sharing), and Biza’s Open Gateway solution covers the Data Recipient side of CDR (accessing CDR data from other institutions). Meaning you can use Biza for all your CDR requirements. ProductCloud does not offer a Holder nor a Recipient solution.
Why this decision matters now
On 3 March 2025, the Australian Government formally extended the Consumer Data Right (CDR) to non-bank lenders. The first hard deadline is 13 July 2026, when initial and large providers must publish Product Reference Data (PRD) via CDR-compliant APIs. Consumer data sharing follows in November 2026 and May 2027.
PRD sounds straightforward. It is not. It covers interest rates, fees, charges, eligibility criteria, and features, all formatted to a Data Standards Body schema that changes regularly. Get it wrong and the ACCC notices, because PRD APIs are public and easy to cross-check against your Product Disclosure Statements.
Warning: The ACCC has a track record of strict enforcement on PRD accuracy. Stale or inaccurate data is not treated as a minor administrative issue.
There is also a strategic question sitting underneath the compliance deadline: do you want one CDR vendor managing both sides of the ecosystem for you, or are you comfortable assembling a multi-vendor stack? For NBLs that intend to both share data (Holder) and consume it (Recipient), that question is worth settling early.
Two purpose-built SaaS solutions have positioned themselves for this market: Biza’s Product Manager module and ProductCloud. Here is how they compare.
Who are they?
BIZA
Pure-play CDR vendor since 2017
Biza built its business exclusively around the CDR ecosystem. It supports more CDR Data Holders than any other provider across banking, energy, and non-bank lending. Its product suite covers both sides of CDR: Holder-as-a-Service (HaaS) and Product Manager for Holder obligations, and Open Gateway for Data Recipient obligations. This dual positioning is unique in the market.
PRODUCTCLOUD
Product governance platform with CDR coverage
ProductCloud is a cloud-based product information management platform for financial services. CDR compliance is one output, but the platform also covers DDO obligations and internal product governance workflows. Its CDR API layer is delivered via a partnership with UK-based Ozone API. It has no Data Recipient solution.
Feature comparison
| Capability | Biza Product Manager | ProductCloud |
| Core purpose | CDR PRD compliance for data holders | End-to-end product information management, including CDR and DDO |
| CDR PRD Compliance | Core focus. Built specifically for this, with schema updates maintained by Biza. | Included. Automated triggers prevent non-compliant PRD from being published. |
| Data Recipient solution | Yes — Open Gateway available as a separate product. A fully managed Data Recipient solution providing accredited CDR data access, consent management, notifications, and branded consumer dashboards. Includes VTT for production testing. Enables a single-vendor model across both Holder and recipient obligations. | Not offered. ProductCloud is a Holder-side product only. Recipient capability would require a separate vendor. |
| DDO compliance | Not offered. PRD only. | Included. Claims to be the only platform combining CDR and DDO in one tool. |
| Single-vendor CDR coverage | Yes. Biza covers both Holder (HaaS incl. Product Manager) and Recipient (Open Gateway) under one provider. One technical team who are CDR standards experts. | No. CDR Holder delivery relies on partnership with Ozone API. No Recipient solution available. |
| Multi-brand support | Yes. Built for the NBL multi-brand model, where the same product is sold under different brand names. | Yes. Multiple brands and portfolios supported. |
| Automated PRD Management | Yes. Both API PRD Management and Bulk Rate updates. |
Unclear. Batch update capability not explicitly stated in public materials. |
| Market insights | Not offered. Compliance-focused only. | Yes. Uses competitor CDR APIs to surface market trends and product comparisons. |
| Full HaaS option | Yes. PM can be purchased standalone or as part of HaaS, full CDR Data Holder compliance (consumer consent, account APIs, infosec, etc.). | Partial. Partnership with Ozone API for broader CDR delivery, but not a single-vendor HaaS. |
|
CDR-only pedigree |
Yes. Built CDR from day one; first ADR-accredited data holder solution vendor. | Partial. Product governance platform that added CDR; relies on Ozone API partnership for API layer. |
| Workflow and approvals |
Basic. Self-service admin console; not the primary focus. |
Yes. Role-based access, approvals workflows, TMD management, and stakeholder reporting. |
| NBL-specific build | Yes. PM explicitly launched for NBLs in March 2025 alongside the CDR rule changes. | Yes. Supports NBLs as a named segment. |
Where each one wins
BIZA
☑️ Longest CDR track record in the market — has navigated every schema change since 2017. CDR is their business, not a feature
☑️ Experienced vendor covering both Holder and Recipient obligations — single team
☑️ Dedicated PRD tooling for NBLs, including the multi-brand complexity most NBLs face
☑️ Bulk rate update capability is operationally significant when rates move
☑️ VTS testing environment reduces go-live risk across both Holder and Recipient scenarios
Limitations
– No DDO functionality — you will need a separate solution if DDO is a current pain point
– No market intelligence features
PRODUCTCLOUD
☑️ Only platform combining CDR and DDO compliance in one tool — genuinely differentiating
☑️ Strong internal governance: role-based access, approvals, stakeholder reporting
☑️ Market intelligence using competitor CDR data is a useful commercial feature
☑️ Product governance scope makes it useful beyond just compliance
Limitations
– No Data Recipient solution — NBLs wanting to consume CDR data need a separate vendor
– CDR delivery relies on a third-party partnership (Ozone API), not a single-vendor solution
– No equivalent to Biza’s VTS for end-to-end compliance testing
– Less public evidence of NBL-specific builds or multi-brand handling
– Smaller team and lower market profile in the CDR space specifically
What to probe before you sign anything
For Biza
Biza’s Product Manager is a module of HaaS, and Open Gateway sits alongside it as the Recipient solution. If you intend to both share and consume CDR data, get clear on how the two are bundled together — there may be commercial upside in taking the full stack from one provider. Also, clarify the pricing model for PM specifically — whether per product, per brand, or flat fee — because NBLs with large product catalogues across multiple brands can see costs diverge significantly. Ask who owns schema updates when the Data Standards Body changes requirements. That should be Biza’s problem, not yours.
For ProductCloud
ProductCloud’s CDR API layer is delivered via its partnership with Ozone API. That is a two-vendor dependency. Understand the contractual structure, who is accountable if something breaks, and what happens if either party exits the partnership. Also, clarify how the DDO and CDR modules are licensed — together or separately? Ask for NBL reference customers specifically, not just banking ADI examples. And if you anticipate needing a Holder and Recipient solution later, understand that ProductCloud cannot provide it.
For both vendors
Ask about implementation support beyond the software. CDR is not a plug-in. You will need help mapping your products to the CDR schema, handling edge cases in your product catalogue, and navigating ACCC queries. Who does that work, and what does it cost?
Which one should a non-bank lender choose?
Choose Biza if:
- Your primary goal is getting CDR-compliant PRD published by July 2026.
- You have multiple brands, and you want a single vendor for both Holder and Recipient obligations — now or in the future.
- You may need full HaaS for consumer data sharing from November 2026.
- CDR expertise and accountability under one roof matter to you.
Choose ProductCloud if:
- You have a DDO compliance gap to close at the same time.
- Your product team wants a governance and workflow tool, not just a compliance widget. Market intelligence on competitor products is commercially valuable.
- You are comfortable managing a multi-vendor CDR stack and have no Consumer Data Obligations nor plans to use CDR data as a Recipient.
If you are in doubt, Biza is the safer default. They have been doing only CDR since 2017, they built the NBL module specifically for this regulatory expansion, and they can provide your entire CDR footprint — Holder and Recipient — without involving a second vendor.
ProductCloud is not the wrong answer if DDO is your burning platform. But you will be assembling a multi-vendor stack for CDR, and that carries coordination risk that compounds over time.
Either way, start the conversation now. July 2026 is closer than it looks.
Disclaimer: The Product Cloud information included in this article is based on publicly available information as at May 2026. It does not constitute legal or compliance advice.
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