The Shape of Things to Come: Regulatory Developments in Canadian Payments 2025

Regulatory updates to Canada's payments ecosystem are reshaping operational risk, compliance obligations and commercial terms across the sector. From interest rate thresholds to anti-money laundering safeguards, there are multiple stand-out shifts.

Staying ahead of the curve is critical, with five key developments to watch:

1. Interest Rate Reforms. New criminal interest rate provisions came into force on January 1, 2025, reducing the rate from a 60% effective annual rate to a 35% annual percentage rate and introducing two new offences: advertising and offering such rates. While certain commercial loans are exempt, interpretive challenges remain, especially with open-credit products like lines of credit and credit cards.
2. Anti-Money Laundering (AML). Regulatory amendments now extend AML obligations to leasing and factoring companies and cheque cashers, requiring entities to implement compliance programs. Also significant are new permissions allowing reporting entities to share personal information with each other without consumer consent and new discrepancy reporting requirements regarding Corporations Canada's beneficial ownership registry.
3. Quebec's Bill 72. Adopted in November 2024, Quebec's Bill 72 introduces stricter consumer lending rules affecting credit card issuers and lenders offering open credit. Requirements include more transparent disclosure of credit limits, updated regulation of membership fees and restrictions on unsolicited credit documentation relating to lines of credit. The bill also strengthens consumer protection by limiting liability for fraudulent fund transfers and preventing certain tipping prompts on terminals.
4. Retail Payment Activities Act (RPAA) and Real-Time Rail (RTR). RPAA amendments introduce enhanced federal oversight of payment service providers, including new registration obligations and operational risk controls. These aim to build confidence in the safety of the Canadian payment landscape while protecting end users from specific risks. Meanwhile, Payments Canada continues work on the RTR payments infrastructure, prioritizing fraud prevention and consumer protection. Drawing on international experience, the RTR could implement tools like confirmation-of-payee protocols and enhanced authentication measures to address the risks of real-time transfers.
5. Code of Conduct. The second phase of updates to the Code of Conduct for the Payment Card Industry in Canada came into effect on April 30, 2025. Key changes include new fee disclosure obligations at the application stage, new notification periods for fee changes and enhanced disclosure requirements in merchant statements. These were in addition to updates that came into effect on October 30, 2024, which included changes to the merchant notification period for non-renewal and the required timelines for responding to merchant Code complaints.

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