Compliance dates stayed; reconsideration under review
As checked October 3, 2026, the CFPB's implementation page still reports that a court stayed the Personal Financial Data Rights Rule's compliance dates on October 29, 2025. Separately, OIRA lists a reconsideration proposal received August 4, 2026 as pending review. A proposal under executive review is not a published final replacement rule or a new compliance timetable. Sources: 1, 2
What changed
The story has shifted from the original phased rollout to litigation and reconsideration. The CFPB's August 2025 advance notice reopened questions about consumer representatives, access fees, data security and privacy. The August 2026 OIRA submission is a later procedural step; its listing does not establish what a final rule will say. Sources: 3, 2
Essential context
The basic idea
Open banking connects a consumer's financial information with services the consumer chooses. In its 2024 framework, the CFPB required covered providers to make data available to consumers and authorized third parties and set obligations for downstream use. Potential applications include bringing accounts into one view and comparing services. Access to account information does not itself transfer a balance or move a recurring payment instruction. Sources: 4
The example applications and distinction between data access and completing a transaction are explanatory analysis.Four dates can describe different things
Publication, effectiveness, a compliance deadline and a court stay are separate events. The rule published in November 2024 specified January 17, 2025 as its effective date and original compliance phases beginning in April 2026 through April 2030. The later stay means that historical schedule should not be presented as a currently running countdown. Sources: 5, 1
How we got here
- Final rule
Final rule published
The Federal Register published the consumer-data framework, with a January 17, 2025 effective date and phased compliance dates. This is the original framework, read alongside the later stay. Sources: 5
- Advance notice
Reconsideration opened
The CFPB requested input on representatives, fees, security and privacy. This advance notice asked questions rather than replacing the rule. Sources: 3
- Court development reported by CFPB
Compliance dates stayed
The CFPB reports that the court in Forcht Bank v. CFPB stayed the rule's compliance dates. This entry reflects the agency's status notice; it does not claim a final judgment on the rule's merits. Sources: 1
- Executive review
Reconsideration proposal received by OIRA
The Office of Information and Regulatory Affairs received RIN 3170-AB39 at the proposed-rule stage. Its record remained marked pending review in this October 3 check. Sources: 2
What remains unresolved
Who will qualify to request data on a consumer's behalf?
The representative question is part of the reconsideration. The final answer could affect the connection between banks, data aggregators and consumer-facing services. Sources: 3
How will access costs, privacy and security be balanced?
The advance notice raises fees and data-protection tradeoffs without adopting a replacement design. Sources: 3
What text and timetable will emerge?
A published proposal, any final rule and subsequent court action would be distinct evidence. The OIRA listing and the old phased dates alone do not settle the outcome. Sources: 2, 1
Primary sources
- CFPB: personal financial data rights implementation status ↗
Source date: Jan 6, 2026
Page's stated last-modified date; checked October 3, 2026
Reported October 29, 2025 stay of compliance dates and identification of reconsideration.
- OIRA: pending review of Personal Financial Data Rights Reconsideration ↗
Source date: Aug 4, 2026
Received date; pending status checked October 3, 2026
RIN 3170-AB39, proposed-rule stage, received August 4 and pending review.
- CFPB: reconsideration advance notice ↗
Source date: Aug 22, 2025
Four reconsideration areas; advance notice status.
- CFPB: original final-rule overview ↗
Source date: Nov 19, 2024
Page's stated last-modified date
Original framework for consumer and authorized-third-party access, downstream obligations and privacy protections.
- Federal Register: original personal financial data rights final rule ↗
Source date: Nov 18, 2024
Publication, original January 17, 2025 effective date and original phased compliance dates.
Targeted review of the primary sources linked on these two pages. Dates describe source events, not a promise of continuous monitoring.