While slow to take off, Canada's mobile payment market is
poised for growth.1 Mobile payments are generally
defined as transactions where payment data and instruction are made
via mobile device, instead of a more traditional method of payment,
such as cash or credit card.2 In Canada, no single
entity has broad regulatory power over the mobile payment
ecosystem. Mobile payments in Canada are governed by a patchwork of
legislation. Regulations are geared toward addressing a variety of
concerns, from setting payments standards to oversight, consumer
protection and security.
The advent of mobile payment systems has enabled new entrants
using financial technology ("FinTech") to compete in a
field conventionally dominated by banks and credit cards. This
relatively new financial service has created challenges for
regulators. A recurrent complaint of incumbents in the space is
that the current regulatory framework makes it difficult for banks
to innovate, while FinTech
