The duty

It is already in force. And it falls every morning.

Since 8 September 2025 a Canadian payment firm has had to keep a written safeguarding framework, and a ledger showing how much of the money it holds belongs to each of its customers at the end of each day. It has to hand that evidence over whenever it is asked for. There is no bill left to pass and no group of firms that has to agree first.

Why the duty exists

Somebody else's money, held by somebody who does not own it.

The duty itself is old and well understood. A lawyer holding your house deposit has always had to account for it. Only the industry it now applies to is new.

1

Money comes in

A customer's pay, deposit or refund lands with the firm.

2

It is not the firm's

It sits in its own account. The firm looks after it and never owns it.

3

Record it daily

At the end of each day, how much is held for each customer. This part the statute asks for by name.

4

Check it and keep it

The record is set against the account the money sits in, any gap is found, and the result is dated and signed.

5

Show it later

An examiner asks about one day, a year and a half after that day.

Being precise about step three, because it is the one most often overstated. The Retail Payment Activities Regulations require a written safeguarding framework, and a ledger setting out the amount of funds belonging to each end user held at the end of each day. They do not set a reconciliation frequency. Checking that ledger against the account daily is how a firm keeps the record true and finds a gap on the day it appears. It is sound practice and it is what this platform does, but it is not a deadline the statute names. Source: Retail Payment Activities Regulations SOR/2023-229, s. 15. Confirm against the current published text.

We never touch the money. We are not a bank and we hold no customer funds. What we produce is the proof the law asks to see.

The duty on a calendar

Thirty six months of proof stand between the start and the first outside check.

The first independent review reads all three years back. A month nobody kept cannot be made up later, at any price.

8 Sep 2025
The duty starts. The Bank of Canada begins supervising retail payment activities.
Today
Eleven months already gone. Most firms kept nothing across them.
8 Sep 2028
The first independent review. An outside firm reads three years of records.
The annual report falls due separately, every 31 March, through the Bank of Canada portal and on a form that changes each year. An incident notice falls due inside forty eight hours of the incident. A notice of a significant change falls due five days before the change is made.
What breaking it costs

Two statutes, two ceilings, and most firms carry both.

Each figure below is the maximum for a single breach, not an annual cap. Every bar starts at zero and they share one scale.

Money laundering rules, the ceiling now CA$20,000,000
Payment rules, a very serious breach CA$10,000,000
Payment rules, a serious breach CA$1,000,000
Money laundering rules, the ceiling before 26 March 2026 CA$500,000

The money laundering ceiling stood at five hundred thousand dollars until 26 March 2026, when it rose roughly forty times. Two smaller amounts belong beside this chart and are far too small to draw next to twenty million: a late notice or report runs five hundred dollars a day, which is fifteen thousand across thirty days. Sources: Bank of Canada retail payments pages and its published penalty policy; Bill C-12 as in force 26 March 2026. Confirm each figure against the current published text before relying on it.

Read it correctly

What the duty is. What it is not.

What the duty is

  • Daily. The record falls due at the end of every day, three hundred and sixty five times a year, and each one is something somebody can ask for eighteen months later.
  • The firm's own. It belongs to the firm holding the money. No bank can carry it on the firm's behalf.
  • Backed by a dated review. An independent examiner reads three years of it, on a date already set in the regulations.
  • Public. The register of firms carrying it is published, with names on it.

What the duty is not

  • Not coming. It is not a proposal, a consultation or a draft. It has been in force since September 2025.
  • Not annual. A yearly duty buys one scramble. A daily one has to become a habit.
  • Not satisfiable in arrears. A record assembled in March from memory is not the record the reviewer is reading for.
  • Not the only one. Most firms carrying it also carry a money laundering duty under a second statute, watched by a second body.
What the platform produces against it