Canadian Bankers Association calls for a comprehensive consumer protection framework for payment services beyond the Retail Payment Activities Act

The Canadian Bankers Association published an article arguing that consumer protection rules for payments should be aligned across banks and newer payment service providers so that similar services deliver a similarly predictable consumer experience. It frames the Retail Payment Activities Act (RPAA) as an important modernization step but says it leaves gaps in market conduct protections governing day-to-day consumer interactions. The article points to a more complex payments landscape in which banks, digital wallets and payment apps can facilitate similar transactions under different consumer protection standards, creating uneven protection and confusion. It notes that the RPAA, in force since 2025, focuses on oversight measures such as risk management and incident response frameworks and safeguarding requirements for money sent through payment service providers, but does not establish comprehensive market conduct rules on disclosures, complaint handling, and what happens when something goes wrong. By contrast, banks are subject to market conduct requirements under the Financial Consumer Protection Framework in the Bank Act, and the article also references work by the G20 and OECD emphasising clear information, accountability and effective dispute resolution as payments become embedded in digital platforms involving multiple parties. The CBA positions the remaining task as closing consumer protection gaps across payment services, and notes it highlighted this approach in its 2025 pre-budget submission to the federal government.