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Canada: Conduct, Safeguarding & Promotions

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The Bank of Canada announced on June 12, 2026 that it will begin publishing Notices of Violation (NOVs) against PSPs, introducing a new public-enforcement-transparency mechanism into the RPAA conduct regime.

Standing sub-brief · as of 8 July 2026160 words · last cycle 2026-08-31

Conduct, Safeguarding & Financial Promotions

The Consumer-Driven Banking Act also received Royal Assent in March 2026, creating a Bank of Canada-administered open-banking and data-sharing supervisory regime with phased participation beginning with large banks. The Consumer-Driven Banking Act allows the Minister of Finance to designate provincial authorities to exercise oversight functions, and establishes a federal-provincial-territorial advisory committee to manage that division of labour. Access to the open-banking regime is structured as an accreditation process for participating entities rather than a conventional licence. Retail Payment Activities Regulations section 15(2)(c) now requires registered PSPs to document how insolvency administrators are expected to handle safeguarded end-user funds, while the Bank of Canada has clarified it does not itself administer insolvency claims. This insolvency-documentation clarification is tracked as a dated procedural item rather than a standing structural change.

Periodic update · new data 2026-09-08

Conduct, Safeguarding & Financial Promotions

Safeguarding of end-user funds is now a live, in-force obligation for registered payment service providers in Canada, not merely a stated policy intention. Since September 8, 2025, registered PSPs have been required to maintain operational risk-management and end-user-funds safeguarding frameworks, and to submit an annual report to the Bank of Canada documenting compliance. The Bank of Canada has finalized a supervisory guideline setting out the expected treatment of end-user funds, structured around segregation of client funds from a provider's own proprietary holdings, giving the safeguarding obligation concrete operational shape rather than leaving it as a general principle.

This is squarely a nonbank PI/EMI-category obligation: registered PSPs, as nonbank payment entities, face this segregation-and-reporting regime directly, distinguishing their conduct obligations from bank-supervised payment activity, which is governed under separate prudential frameworks rather than the RPAA's safeguarding provisions. The annual-report requirement to the Bank of Canada gives the regulator an ongoing compliance-monitoring mechanism beyond the initial registration decision, meaning safeguarding compliance is subject to continuing supervisory review rather than a one-time gate at registration.

Outlook

The first cycle of annual safeguarding reports from registered PSPs, now that the September 2025 requirement has been in force for a full year, will be the next concrete test of how the segregation guideline is being applied in practice across the registered population.

1 earlier distinct update(s)

Periodic update · new data 2026-08-26

Conduct, Safeguarding & Financial Promotions

The defining conduct-regime development this cycle is the Bank of Canada's June 12, 2026 announcement that it will begin publishing Notices of Violation (NOVs) against payment service providers once the representation period following a finding expires. Published notices will include the nature of the violation and any administrative monetary penalty amount, and will remain publicly accessible for five years. This is the first public-enforcement-transparency mechanism introduced into the RPAA conduct regime, and it applies across both bank and non-bank PSPs alike — unlike the safeguarding-framework obligation covered under W1a, which is calibrated specifically to the non-bank population.

The mechanism's design — publication only after the representation period expires, and a five-year public retention window — gives affected PSPs a defined procedural opportunity to respond before a violation becomes public, while ensuring a durable reputational record once published. For compliance and conduct functions inside PSPs, this materially raises the stakes of any RPAA conduct finding: previously private regulatory correspondence about a violation now carries a foreseeable path to public disclosure.

This conduct-transparency shift should be read alongside the safeguarding-framework requirement in force since September 2025 as two halves of the same underlying trend: the RPAA regime is moving from a private, registration-based supervisory relationship toward one with public accountability mechanisms attached to both prudential and conduct dimensions.

Outlook

The first published Notices of Violation, once they begin appearing under this June 2026 commitment, will be the first concrete test of how the mechanism operates in practice, including how the Bank of Canada characterizes violation severity and how frequently NOVs are published relative to the underlying RPAA-registered PSP population.

Sources and findings (4)