Expedited compliance process for Payments Canada

Summary#

This is a proposed change to Canadian Payments Association By-law No. 6 — Compliance, published in the Canada Gazette on October 11, 2025. It would let Payments Canada use a faster process for simple or uncontested member rule breaches and raise the maximum monetary penalty from $250,000 to $1,000,000 per contravention.

What it does#

• Lets the President of Payments Canada investigate some alleged breaches directly, without sending the matter to a committee, when the case is simple or uncontested.
• Sets shorter time limits for that faster process:
  • parties can submit a written response and evidence within 10 days after notice;
  • the President must issue a written decision within 20 days after notice.
• Gives members the right to ask for an independent review of the President’s decision by a compliance panel:
  • a review request must be made within 30 days;
  • the President must refer a review request to a committee within 5 days;
  • the compliance panel must give its written decision within 30 days after it is established.
• Increases the maximum penalty that can be ordered for each contravention from $250,000 to $1,000,000.
• Updates some definitions and wording to reflect current practice and recent legislative changes.
• The by-law would come into force on the day section 222 of the Fall Economic Statement Implementation Act, 2023 comes into force, or on the day the by-law is registered (whichever is later).

Who's affected#

• Members of Payments Canada. That includes major banks, credit unions and their locals, clearing houses, and payment service providers that participate in national payment systems.
• Small businesses that are members of Payments Canada could be affected if they are investigated for a contravention.
• The general public is not directly regulated by this by-law, but users of payment systems could be indirectly affected if enforcement changes how members operate.

Why it matters#

• Faster investigations mean less time and administrative cost for both Payments Canada and members when issues are straightforward or uncontested.
• A higher maximum penalty ($1,000,000) is intended to keep monetary sanctions meaningful over time and to encourage compliance.
• In practice, members facing a serious finding could face much larger fines than before. If a member pays a penalty, they generally cannot seek the independent review of the President’s decision.
• These changes aim to make Payments Canada’s enforcement quicker and stronger, which could affect how payment-system participants manage compliance and risk.