The quiet proof the PRDE didn't work, and why it shouldn't be renewed on autopilot.
There is a simple test for whether a policy works: does it achieve its purpose on its own? By that test, the Principles of Reciprocity and Data Exchange (PRDE), the framework now before the ACCC for re-authorisation, has already given us the answer.
A telling piece of history
Comprehensive credit reporting was meant to be delivered through voluntary reciprocity under the PRDE: contribute your data, and you get access to everyone else's. The logic is sound. The problem is that it did not work well enough, participation from the largest data holders, the major banks, was slow and partial.
So the government did something revealing. In 2021 it passed the National Consumer Credit Protection Amendment (Mandatory Credit Reporting and Other Measures) Act, compelling the big banks to report comprehensively. Comprehensiveness, in other words, had to be mandated by law.
Why that matters for the ACCC's decision
The ACCC can only authorise the PRDE if its public benefits outweigh its harm to competition, and if those benefits cannot be achieved by less restrictive means. But the central benefit the PRDE is credited with, comprehensive data, is now secured by statute. If the outcome is already delivered by legislation, the case that a competition-law exemption is still necessary becomes very weak.
To be fair, industry supported mandatory reporting, and the two instruments are not in direct conflict. But the inference is hard to avoid: if reciprocity had to be propped up by legislation, it was not sufficient on its own.
A governance problem too
There is a second issue. The PRDE is developed and administered through structures created by the legacy bureaus themselves, the same participants whose commercial interests are most affected. Asking an industry body to independently police its own most powerful members is a structural conflict, not a governance model.
Keep the data, drop the lock-in
None of this means abandoning good data. It means achieving it without entrenching a concentrated market. Comprehensiveness is already mandated. Any remaining benefit of reciprocity could be delivered through an independent, centrally administered credit-data registry, modelled on the Integrated Public Number Database in telecommunications and on the public credit registries that central banks operate overseas, rather than through a framework run by the legacy bureaus. Competition would then happen where it should: on analytics and service, not on control of the data.
We know it can be done, because we are doing it. TaleFin delivers comprehensive, real-time credit insight to lenders today, without the PRDE's protection. Innovation is not the barrier. The framework is. That is why we have asked the ACCC not to renew the PRDE in its current form. Renewal shouldn't be automatic, it should be earned.