Expedited Compliance Process for Payments Canada

Summary#

This is a proposed amendment to By-law No. 6 — Compliance of the Canadian Payments Association (doing business as Payments Canada) published on October 11, 2025. It would let the President handle straightforward or uncontested rule breaches more quickly and raise the maximum monetary penalty for each contravention from $250,000 (set in 1998) to $1,000,000.

What it does#

• Creates an expedited investigation route where the President can investigate simple or uncontested alleged contraventions without referring the matter to a committee.
  • Parties can provide a written response and evidence within 10 days after notice.
  • The President must issue a written decision within 20 days after notice.
  • The President can refer the matter to a committee at any time if it turns out to be more complex.
  • A party can ask for an independent review by a compliance panel within 30 days of the President’s decision (but not if the ordered penalty has already been paid).
  • Existing committee-based processes (including hearings) remain available for more complex or disputed cases; referrals to committee must happen within 40 days for member-filed complaints.
• Increases the maximum monetary penalty per contravention from $250,000 to $1,000,000.
• Updates some definitions and wording in the by-law for clarity and to reflect recent legislative changes.
• Specifies the by-law would come into force on the later of the day section 222 of the Fall Economic Statement Implementation Act, 2023 comes into force or the day the by-law is registered.

Who's affected#

• Members of Payments Canada — banks, large payment system participants, clearing houses, and other eligible payment entities who must follow Payments Canada’s by-laws and rules.
• Payment service providers, credit union locals and cooperative credit associations that interact with Payments Canada systems.
• Small businesses only if they are actual members of Payments Canada; otherwise the changes mainly affect members and participants in national payment systems.
• Payments Canada itself — because the change changes how investigations are run and how penalties are set.
• If a member is alleged to have breached a rule, that member and any directly involved parties would be the ones to face faster investigations or larger possible fines.

Why it matters#

• Faster, simpler cases could be resolved much more quickly, reducing the time and administrative effort for both Payments Canada and the organizations under investigation.
• The higher maximum penalty (up to $1,000,000) is intended to keep fines meaningful and encourage compliance. It means a contravention that today could lead to a maximum fine of $250,000 could, under these rules, attract a much larger penalty.
• For most businesses this is an internal industry enforcement change — it won’t affect everyday bank customers directly — but it matters to firms that participate in Canada’s national payment systems because it changes how compliance and discipline are handled.
• This is a proposed amendment, not final law. Comments are invited for 30 days after the notice was published (publication date: October 11, 2025).