Fintechs Canada has filed two submissions with the federal government as part of Finance Canada’s consultation on proposed amendments to the Canadian Payments Act’s regulations and by-laws. The association backed the reforms, but also urged the government to refine them to support stronger governance and greater transparency.
The consultation follows recent legislative changes to the Canadian Payments Act that created a new category of members for Payments Canada. With that expansion, several by-laws and regulations now require updates to reflect the broader set of organizations participating in Payments Canada’s systems.
Fintechs Canada represents a wide range of financial technology firms, from Canadian fintechs to global companies and technology providers serving credit unions. Its members serve millions of Canadians each day, and the association regularly engages on policy issues that affect innovation, competition, and the stability of the financial system.
In its submission on proposed changes to the Canadian Payments Association Compliance By-law, published in the Canada Gazette on October 11, 2025, Fintechs Canada said it supports amendments that would let the President of Payments Canada investigate straightforward compliance matters, raise the maximum administrative monetary penalty to $1 million, and modernize key definitions and procedures. These measures, it wrote, “will help Payments Canada administer compliance more efficiently and proportionately as the payments ecosystem continues to evolve.”
The association recommended that Payments Canada publish guidance explaining how the President will exercise discretion and how penalties will be calibrated, noting that organizations such as FINTRAC and the Financial Consumer Agency of Canada “regularly release decision criteria and anonymized outcome summaries to promote fairness, transparency, and predictability.”
In a separate submission on proposed changes to the Canadian Payments Association Election of Directors Regulations, Fintechs Canada supported opening eligibility for independent directors and shortening the cooling-off period for individuals previously affiliated with Payments Canada or its members. The association said the reforms recognize that “a much wider range of entities are now regulated and contributing to the safety and efficiency of Canada’s payments ecosystem—even if they are not members of Payments Canada itself.”
It added that expanding eligibility to individuals from non-member payment service providers would strengthen oversight by bringing in “a broader range of industry expertise and operational perspectives.”
On the reduced cooling-off period, Fintechs Canada wrote that the change “will also make it easier for Payments Canada to attract highly qualified candidates with recent, relevant experience in payments but no ongoing conflicts of interest,” helping refresh the board “while preserving the independence that underpins public confidence in Payments Canada’s decisions.”
The association called the reforms “sensible and overdue,” saying they align Payments Canada’s governance with “a more open, diverse, and technology-driven financial system.”
For the full submission on the compliance regulations, click here. For the full submission on the election of independent directors, click here.
