Supporting a multi-sector approach to safeguard Canadians in the new era of payments

Payments Canada’s response to the federal consultation on the National Fraud Strategy.

Payments Canada has submitted its feedback to the Department of Finance’s consultation on the proposed National Anti-Fraud Strategy. As the operator of Canada’s critical national payment clearing and settlement infrastructure, Payments Canada strongly supports a coordinated, multi-sector and forward-looking response to protect Canadians and maintain trust in the evolving financial ecosystem. 

Key pillars of the submission: 

• Multi-sector collaboration: A multi-sector approach that unites the financial sector, telecommunications providers and digital platforms will help to address the full lifecycle of fraud, providing a strong foundation for mitigating risks.
• Payment modernization: As payment systems become faster and more data-driven, they will unlock economic benefits for Canadians. Requiring standardized fraud prevention, detection, monitoring and response capabilities for system access will be critical to ensuring ongoing security.
• Consistent regulation: With the expansion of Payments Canada membership, anti-fraud requirements must be applied proportionately and consistently.
• Enhanced information sharing: Sharing data across sectors and with regulators is another vital for early threat detection. This must be governed by a clear data governance framework that is purpose-driven, proportionate and carefully designed to respect Canadians' privacy rights and legal protections.
• Coordinated oversight: Payments Canada recommends a coordinated oversight model that includes both a central coordinating function and sector-specific regulators to ensure fair, predictable outcomes across different industries. This also includes coordination with international partners to support more aligned approaches to fraud prevention, detection and response across jurisdictions.
• Consumer education: Informed consumers remain an essential line of defense. Payments Canada supports initiatives that deliver coordinated, consistent messaging to help Canadians better recognize fraudulent activity, alongside clear reporting channels and efficient, timely dispute resolution processes.
• Law enforcement support: Fraud is often cross-border and multi-jurisdictional. Payments Canada supports sharing ecosystem insights with law enforcement, provided appropriate safeguards are implemented to ensure alignment with privacy requirements and legal protections. 

Moving forward, Payments Canada remains committed to collaborating closely with federal and provincial policymakers, regulators and industry stakeholders to deliver a forward-looking strategy that protects Canadians from evolving financial crimes.

Read the full submission below.

Written submission to the Department of Finance’s consultation on a National Anti-Fraud Strategy

Payments Canada welcomes the opportunity to provide input to the Government of Canada’s consultation on the development of a National Anti-Fraud Strategy, particularly as it relates to the payment ecosystem. In fulfilling its mandate as the operator of Canada’s core payment clearing and settlement infrastructure, Payments Canada supports a payment ecosystem that is secure, resilient and maintains the trust of Canadians.

Established by the Canadian Payments Act and overseen by the Minister of Finance and the Bank of Canada, Payments Canada is the national, public purpose organization responsible for Canada’s critical payment infrastructures. Payments Canada ensures the secure, efficient and reliable exchange of hundreds of billions of dollars every day. From processing payroll and settling household bills to facilitating complex global commerce, every Canadian, along with businesses, institutions and governments relies on the national payment 'rail' infrastructure to move money safely. In 2025 alone, Payments Canada’s infrastructure cleared and settled $103 trillion, more than $411 billion every business day.

Payments Canada’s role is evolving beyond being a trusted utility provider. Our vision, to enable prosperity, productivity and safety for Canada through trusted, world-class payments, reflects our role as a strategic partner that facilitates economic growth, social progress and efficiency; delivers nation-building payment system infrastructure; and acts as a steward of the Canadian payment ecosystem at large.

Overview

Fraud within the payment ecosystem is evolving rapidly, requiring proactive, system-wide responses to protect Canadians and maintain trust. Payments Canada is advancing efforts to strengthen fraud detection and prevention measures, including risk-based controls and safeguards, in close collaboration with financial institutions and stakeholders.

As noted in the discussion paper, fraud is increasing in both scale and sophistication, with fraudsters leveraging new technologies and operating across sectors and jurisdictions. Addressing these challenges requires coordinated action across the ecosystem.

Payments Canada’s views on the government’s consultation

Multi-sector approach to fraud
Payments Canada supports the development of a multi-sector approach that recognizes the interconnected roles of the financial sector, telecommunications providers and digital platforms. Fraud schemes frequently span these sectors, with fraudsters exploiting communication gaps between them to deceive individuals and facilitate the illicit movement of funds.

The proposed Multi-Sector Anti-Fraud Framework provides a foundation for addressing these risks. Its focus on prevention, detection, disruption and response reflects the full lifecycle of fraud and supports a more coordinated approach across sectors. The inclusion of these three sectors should be broadened from the initial phase to include all relevant sectors, including new and emerging sectors to ensure a comprehensive approach to fraud. This includes Retail Payment Activities Act (RPAA)-regulated payment service providers, which helps to ensure the Framework remains aligned with the evolving structure of the payment ecosystem and Payments Canada’s expanded membership.

Payment ecosystem evolution and fraud mitigation
Canada’s payment ecosystem is undergoing significant evolution to meet the needs of Canadians and the broader economy. Payments Canada is implementing the Real-Time Rail (RTR), which will enable faster, 24/7/365 payments, while supporting data-rich payments and the development of innovative payment products and services.

At the same time, Payments Canada has been advancing the adoption of ISO 20022 in Canada, a global messaging standard that enhances the quality and structure of payment data. The transition to data-rich payments is expected to support improved fraud detection and analytics by enabling more detailed and timely insights into payment activity.

As payment systems become faster and more data-driven, they will unlock economic benefits for Canadians but also introduce new risks, particularly the targeting of real-time authorized payment fraud by bad actors (where individuals may be deceived into initiating transactions). This highlights the need for controls that operate in real time. Requiring standardized fraud prevention, detection, monitoring and response capabilities to access payment systems will be critical to ensuring efforts continue to support both efficiency and security.

In addition, exploring the use of advanced technologies, including artificial intelligence, will also be important to keep pace with the increasing scale and sophistication of fraud and to support more effective detection and prevention efforts.

As the payment ecosystem evolves, so does the range of participants involved. Payments Canada’s membership has recently expanded to include a broader range of entities, including payment service providers and other non-federally regulated participants. These participants play an increasingly important role in the movement of funds and the delivery of payment services to Canadians. As such, it will be important that the development of the Strategy and any associated Framework consider the roles, responsibilities and capabilities of all payment system participants, ensuring that requirements are applied in a manner that is proportionate, consistent and reflective of the evolving structure of the ecosystem.

Information sharing and coordination
Within a clear and effective data governance framework, Payments Canada supports enhanced information sharing across sectors and with regulators as a key enabler of effective fraud prevention and response. Timely and targeted sharing of fraud-related information can improve the ability of organizations to identify emerging threats and take action to prevent further harm.

In particular, the ability to share insights derived from payment data, including transaction patterns and indicators of suspicious activity, could support earlier detection and disruption of fraud schemes across sectors. At the same time, such information sharing must be carefully designed to ensure it is purpose-driven, proportionate and factors in privacy rights and legal considerations.

Establishing clear parameters around when information should be shared, what information is appropriate to share and how it can be used will be fundamental to enabling effective collaboration while maintaining public trust.

Governance, oversight and accountability
Payments Canada supports a coordinated oversight model that includes both a central function and sector-specific regulators. A central coordinating body could support consistency across sectors and facilitate a more integrated view of fraud risks, while sector-specific regulators would continue to oversee obligations within their respective areas.

As the Framework evolves, consideration should be given to how accountability and obligations are structured. Given that fraud often involves multiple touchpoints across sectors, a clear and balanced approach to responsibility will be important to ensure that obligations are understood and that outcomes for stakeholders are fair and predictable.

As part of this approach, it will also be important to support collaboration and coordination between federal and provincial regulators in the development and implementation of anti-fraud measures, to help avoid duplicative or contradicting requirements.

Given that fraud is a global issue, a concerted effort to coordinate with international partners will be important. Strengthening international collaboration can improve information sharing and support more aligned approaches to fraud prevention and response, enhancing the ability to detect and disrupt fraud that operates across jurisdictions.

Consumer awareness and outcomes
Payments Canada supports efforts to strengthen consumer awareness and education as part of the Strategy. As fraud schemes frequently rely on deception and social engineering, informed consumers are an important line of defence. These risks are evolving with the use of emerging technologies, including artificial intelligence, which can enable more convincing and targeted fraud attempts at scale.

Advancements in payment technologies, including real-time payments, further reinforce the importance of ensuring that consumers understand how and when payments are initiated and the associated risks. Coordinated and consistent messaging across sectors can help Canadians better recognize fraudulent activity and respond effectively.

Ensuring that consumers have access to clear reporting channels and timely, efficient resolution processes will be important to improving outcomes and maintaining confidence in the financial system.

Law enforcement
Payments Canada recognizes the importance of law enforcement’s ability to combat fraud. Given the cross-border and multi-jurisdictional nature of many fraud schemes, effective collaboration across agencies and jurisdictions will be essential.

Insights derived from across the ecosystem may help inform investigations and support more targeted enforcement efforts. Any such measures should be implemented with appropriate safeguards to ensure alignment with privacy requirements and applicable legal protections, including clarity on how these protections apply to entities sharing information for the purposes of fraud prevention, detection and response.

Conclusion

Payments Canada supports the Government of Canada’s initiative to develop a National Anti-Fraud Strategy and encourages ongoing collaboration between federal and provincial policymakers, regulators and industry stakeholders.

A coordinated and forward-looking approach that reflects the evolving nature of fraud, alongside the ongoing evolution of Canada’s payment systems, will be essential to protecting Canadians and maintaining trust in the financial system.