Payments Canada: Expedited Compliance Process

Summary#

This is a proposed amendment to Canadian Payments Association By-law No. 6 — Compliance (Payments Canada’s compliance rules). It would let the President of Payments Canada use a faster process for straightforward or uncontested rule breaches and raise the maximum fine for each breach from $250,000 to $1,000,000. The proposal was published in the Canada Gazette, Part I on October 11, 2025, and is open for comment for 30 days after that date.

What it does#

• Creates an expedited investigation route where the President can investigate a simple or uncontested alleged contravention without sending the matter to a committee.
  • Parties would have 10 days to provide a written response and evidence after the President’s notice.
  • The President must issue a written decision within 20 days of that notice.
  • If a party disagrees, they can ask for an independent review by a compliance panel within 30 days of the President’s decision.
  • At any time the President can refer the matter to a committee if it turns out to be more complex.
• Increases the maximum monetary penalty for each contravention from $250,000 to $1,000,000. Other sanctions (for example, reprimands or suspensions of rights) remain available.
• Updates some definitions and wording in the By-law to reflect current practice and recent legislative changes.
• Ties when the By-law would take effect to certain sections of the Fall Economic Statement Implementation Act, 2023 and to the date the By-law is registered (the Gazette text mentions section 222 and also refers to sections 219 to 228; the document is not fully consistent on that point).

Who's affected#

• Members of Payments Canada and participants in its payment systems.
• Non-member local credit unions that belong to a central or cooperative credit association that is a Payments Canada member (referred to in the By-law as “non-members”).
• Payment service providers, clearing houses, and similar organizations that the consultations named as stakeholders.
• Small businesses only if they become members of Payments Canada and are alleged to have breached the By-law.
• Compliance panels and officials inside Payments Canada (because of new procedures and timelines).

If it is unclear who will be affected in a specific case, the By-law’s definitions and Payments Canada’s rules determine membership and coverage.

Why it matters#

• Faster resolutions: Simple or uncontested compliance issues could be investigated and closed much quicker, with no full hearing. That reduces time and administrative burden for both Payments Canada and members.
• Bigger potential fines: The top penalty for each breach would jump to $1,000,000, so the financial risk for serious non-compliance would be larger than under the current $250,000 cap.
• More predictable process: The new short timelines (responses in 10 days, decisions in 20 days) create clearer expectations about how fast a case will move.
• Limited impact unless you breach the rules: Most people and firms will only notice a difference if they are a Payments Canada member or are investigated for non-compliance. The proposal says there are no new costs to taxpayers and that small businesses are unlikely to face added costs unless they are members and found to have contravened the By-law.
• This is a proposal, not final law. Interested parties were invited to make representations within 30 days after the Gazette publication on October 11, 2025.