One Step Closer To A Regulatory Regime For Payment Service Providers - Draft Retail Payment Activities Regulations Released

Since the threats of new and increased U.S tariffs first emerged in the spring, the Ontario government has looked to reduce trade barriers and improve harmonization for licensing standards between provinces.

The 2026 Federal Budget (“Budget 2026”) proposes to grow the Canadian financial services sector, while introducing multiple checks on possible risks raised by new bank entrants and innovative technology. It also builds out existing policy measures to support digital innovation and combat fraud. There are various other measures that may be of interest to financial service providers in banking, insurance and payments.

Expanding a payment business into Canada requires navigating FINTRAC's Money Services Business registration framework. Understanding the regulatory requirements, compliance obligations, and practical steps for MSB registration helps international payment providers establish compliant operations in one of the world's most established financial markets.

The Office of the Superintendent of Financial Institutions (OSFI) published its third quarterly release of the year on September 10, 2026, noting that the targeted adjustments made to its guidance were made with a view to supporting a resilient and competitive Canadian financial system.

The Bank of Canada (the “Bank”) has published two proposed guidelines relating to the accreditation process for prospective participants under the Consumer-Driven Banking Framework: the Participating entity accreditation application requirements under the Consumer-Driven Banking Act (the “Participating Entity Guideline”) and the Third-party service provider accreditation application requirements under the Consumer-Driven Banking Act (the “TPSP Guideline”).

The Canadian Investment Regulatory Organization’s (CIRO) proposed Incorporated Approved Person model could materially change how client-facing advisors structure their businesses and receive compensation with significant impacts to sponsoring firms. The proposed rule amendments, published on July 9, 2026, would introduce a harmonized incorporated compensation option for client-facing Approved Persons across CIRO regulated dealers. Comments are due November 6, 2026.

Bill C-12 has fundamentally transformed Canada's anti-money laundering framework by introducing penalties up to forty times higher than previous levels and expanding compliance obligations across the financial sector. The legislation now requires all reporting entities to enroll with FINTRAC and maintain "reasonably designed, risk-based and effective" compliance programs, while imposing cumulative maximum penalties that can reach 3% of global revenue.

On October 13, 2026, British Columbia’s new Mortgage Services Act, S.B.C. 2022, c. 27 (the “MSA”) will come into force and effect, replacing the longstanding Mortgage Brokers Act, R.S.B.C. ch. 313 (the “MBA”). The MSA introduces a modernized regulatory framework for mortgage service providers, including expanded licensing requirements, increased disclosure obligations, enhanced enforcement tools, and significantly higher penalties for non-compliance.

This Bulletin summarizes key regulatory developments impacting the payments sector in 2025 and looks ahead to 2026.

Following a consultation period with consumer groups and the banks, the federal government has amended the Financial Consumer Protection Framework Regulations under the Bank Act (the Amendments)...

A regulatory shift now under consideration in Ontario could reshape how the province’s medical aesthetic clinics operate. The proposal, which would change how nurses are authorized to administer medical aesthetic services, invites a broader look at how Ontario currently regulates cosmetic injections and how the proposed changes would align the province more closely with the regulatory frameworks already in place elsewhere in Canada. While these procedures are often marketed as routine “spa” services, they remain medical acts that involve prescription products and carry clinical risks.

Starting November 1, 2026, BC's pay transparency reporting obligation expands to cover employers with 50 or more employees, significantly broadening the scope of the Pay Transparency Act and Pay Transparency Regulation (the "Act").

These ailments are usually short-term conditions, which can be reliably self-diagnosed and managed with minor treatment and minimal follow-up care.

The 2026 Federal Budget (“Budget 2026”) proposes to grow the Canadian financial services sector, while introducing multiple checks on possible risks raised by new bank entrants and innovative technology. It also builds out existing policy measures to support digital innovation and combat fraud. There are various other measures that may be of interest to financial service providers in banking, insurance and payments.

Effective September 8, 2026, Canada implemented retaliatory tariffs on certain U.S. goods in response to the initial 50% tariffs imposed by the US under Section 338 of the Tariff Act of 1930. To operationalize these measures, the Canada Border Services Agency (CBSA) issued Customs Notice 26-23, establishing binding administrative rules on how the surtax will be applied, calculated, and collected.

The Office of the Superintendent of Financial Institutions (OSFI) published its third quarterly release of the year on September 10, 2026, noting that the targeted adjustments made to its guidance were made with a view to supporting a resilient and competitive Canadian financial system.

The Bank of Canada (the “Bank”) has published two proposed guidelines relating to the accreditation process for prospective participants under the Consumer-Driven Banking Framework: the Participating entity accreditation application requirements under the Consumer-Driven Banking Act (the “Participating Entity Guideline”) and the Third-party service provider accreditation application requirements under the Consumer-Driven Banking Act (the “TPSP Guideline”).

On July 29, 2026, Health Canada announced that it had obtained a permanent injunction against a Québec-based company in connection with the sale of unauthorized injectable peptides in Canada. The announcement reflects Health Canada’s continued focus on peptide products and serves as a reminder that injectable peptides intended for human use are regulated as prescription drugs and are subject to Canada's drug regulatory framework.

A new regulatory framework for measuring and monitoring the energy performance of Québec’s building stock took effect on July 8, 2026, under the Regulation respecting the mandatory reporting of the environmental performance of certain buildings (the “Regulation”).

This Bulletin summarizes key regulatory developments impacting the payments sector in 2025 and looks ahead to 2026.