Real-Time Rail public consultation reconfirms strong industry support for Canadian real-time payment system

Feedback considered for potential rule amendments.

Between May 20 and July 2, 2025, Payments Canada conducted a public consultation to seek input on the proposed legal framework that will govern the forthcoming Real-Time Rail (RTR), supporting the system’s safety, efficiency and soundness. The RTR legal framework was developed in close collaboration with members, regulators and industry stakeholders and was consulted on publicly to provide transparency and clarity on the draft RTR By-law, draft rules and policy elements.

Engagement in the public consultation process, which was supported by a series of educational webinars on key aspects of the framework, was high and confirmed support for the RTR system and its core objectives. Consultation responses have informed the RTR legal framework, as well as the onboarding of new participants.

The consultation received submissions from Payments Canada’s current members, prospective members (including payment service providers, clearing houses and credit union locals), stakeholder groups, associations and consumer representatives.

Many submissions spoke to the importance of risk-based access to the RTR in enabling competition, innovation and better payment products and services for Canadians. Responses generally acknowledge the necessity and benefit of key components, such as financial risk measures and centralized fraud services, recognizing their role in enhancing the security and collective fraud detection capabilities.

Respondents also provided Payments Canada with valuable feedback to consider as part of the RTR rules and in associated guidance, including:

• Fraud initiatives: Overall, feedback was supportive of the requirements for the use of fraud tools for RTR participants, including the four centralized fraud services (Confirmation of Payee (CoP), Central Risk List, Central Fraud Analytics and Central Fraud Reporting). However, some respondents asked for clarity on the fraud requirements, including reporting, corresponding enforcement actions and recourse mechanisms for both participants and end-users in the event of fraud incidents. Additionally, some respondents sought clearer operational details for CoP, including expectations around response times, minimum matching requirements and accountability for responding banks.
• Final and irrevocable payments: Some feedback posed questions regarding the finality and irrevocability of RTR transactions. RTR payments are settled immediately on a final and irrevocable basis – they cannot be recalled by a sending participant. Typically, once settled, the payment amount is made available to the payee in real-time. As a retail payment system, the proposed rules accommodate exceptions to the finality and irrevocability of payments made available to the payee. The receiving participant may initiate a return in situations where an exception is identified, such as in the case of fraud or errors, which are processed as an optional second transaction. This approach supports efficient error resolution and restitution in cases of fraud, considering the interests of both payees and payors and promoting confidence in this new retail system. Payments Canada’s policies for handling exceptions align with international benchmark standards, including those of The Clearing House’s Real-Time Payments (RTP) network and FedNow (US), for addressing errors, unauthorized transactions and fraud in real-time systems.
• Participant access and third-party roles: There was support for tiered access to the RTR allowing smaller institutions to access the payment system, promoting competition and innovation within the payment ecosystem. Responses raised a need for some clarification on the criteria and processes for third-party exchanges (TPEs) to connect and meet RTR fraud requirements. Respondents also requested a clearer understanding of the definitions and differences between competitive services, connection service providers and TPEs, including their respective roles and responsibilities.
• Compliance and reporting: Some feedback highlighted the need for additional guidance on what compliance means for different participant types. Respondents also requested clarification on the processes for participant suspension, reinstatement, compliance monitoring and revocation of access, including the impacts on other participants. The proposed reporting requirements align with Payments Canada’s requirements for Lynx and the ACSS.
• Incident notification: General feedback highlighted concerns that the incident notification timeframe of “no longer than five minutes” may be operationally challenging for many financial institutions due to engagement with multiple vendors and complex infrastructure. While we recognize that a five-minute notification timeframe may be operationally challenging, it is essential that incidents preventing a participant from exchanging, clearing or settling RTR messages are reported within this timeframe to mitigate the impact on other participants.
• Claims and complaint handling: Some respondents indicated that the requirements for participants to have internal policies to deal with claims or complaints and to be a member of an External Complaints Body could be incompatible or overlap with existing regulatory requirements. Payments Canada is amending its rules to distinguish between an External Complaints Body, as that term is defined in federal legislation, from a “Complaints Body” for the purposes of participating on the RTR. Additionally, changes will be made to clarify that this requirement should not apply to participants that do not interact with consumers or small businesses.

Payments Canada would like to thank all of those who submitted a response to the public consultation. The feedback is invaluable in helping Payments Canada in preparing for the launch of Canada’s real-time payment system. Payments Canada will continue to work with members, participants, ecosystem and its regulators to address feedback.

If you have any questions or comments relating to the consultation process, please contact consultation@payments.ca.