Merchant services

Code of Conduct for the Payment Card Industry in Canada

The Code of Conduct for the Payment Card Industry gives Canadian merchants fee notice, a penalty-free exit, clear pricing and card choice. Here's how it works.

Clearo Payments teamFacts checked 9 min read

Short answer

The Code of Conduct for the Payment Card Industry in Canada is a set of commitments the card networks have adopted and FCAC supervises. In its current form since October 30, 2024, it requires clear fee disclosure, 30 to 60 days' notice of fee increases, and a penalty-free exit within 70 days of a change, and it lets merchants choose which cards to accept.

The Code of Conduct for the Payment Card Industry in Canada is the rulebook that governs how card networks and payment processors treat Canadian merchants. The major networks have committed to it, the Financial Consumer Agency of Canada (FCAC) supervises compliance, and its obligations flow down to the processors and sales agents who sign you up. For a business owner, it does four practical things: it makes your processor disclose every fee, it requires notice before fees go up, it lets you leave without penalty when they do, and it gives you a say in which cards and payment options you accept.

The current version has applied since October 30, 2024. This guide explains what the Code protects, what it doesn't, and how to use it, with dates worked through. It draws on FCAC's published Code and merchant guidance as of October 2026. If you're opening an account, read it alongside our guide to getting a merchant account in Canada.

What is the Code of Conduct for the Payment Card Industry?

It's a set of market conduct commitments for the payment card industry, first introduced in 2010. FCAC says all the major payment card network operators in Canada have agreed to it: American Express Canada, Discover, Interac, Mastercard Canada, Visa Canada, and UnionPay. FCAC monitors how the networks put it in place and supervises their compliance (FCAC).

FCAC describes three goals for merchants:

  1. Make sure you know the full cost of accepting payment cards, so you can reasonably forecast your monthly costs.
  2. Give you more pricing flexibility to encourage customers to use lower-cost payment options.
  3. Let you choose which payment options to accept.

The current Code took effect on October 30, 2024. Its predecessor was called the Code of Conduct for the Credit and Debit Card Industry in Canada, and you'll still see that name in older contracts and articles.

Who has to follow the Code?

The card networks, the acquirers that hold merchant accounts, and the companies working downstream of them, which covers payment processors and their sales agents. If a company signs you up to accept Visa, Mastercard, Interac, or the other participating networks, the Code's obligations reach it through the network.

It isn't a provincial statute, and FCAC doesn't settle individual disputes under it. FCAC describes industry codes as market conduct obligations: companies that commit to a code are obligated to comply with it (FCAC). In practice, your protection comes from two places: your processor's own duty to follow the Code, and FCAC's ability to look into a network whose participants don't.

What fee disclosure does the Code require?

Every fee in writing before you sign, and a clear monthly statement after. Merchant agreements that include card processing must start with a cover page, an information summary box, that sets out prescribed information. The agreement also has to include a Cost per Transaction Disclosure and a Disclosure of Fees (FCAC merchant rights).

What you getWhenWhat it shows
Information summary boxAt signingPrescribed key information on a cover page, including terminal details if your processor offers one
Cost per Transaction DisclosureAt signingA required part of the agreement, alongside the fee list
Disclosure of FeesAt signingThe fees you can be charged
StatementAt least monthlyYour rates, plus totals for interchange, network assessment fees, and all other fees
Notice of rate cuts not passed onWhen networks lower feesWhether network fee reductions will reach you in full

The terminal part catches people. If your processor offers a terminal, the summary box has to say whether it's bought, rented, or leased, list the fees, and give the end date and any early termination fees. A lease you sign on your own initiative with an unrelated company counts as a separate agreement, so these protections may not reach it. Our guide to choosing a debit machine covers the lease trap in detail.

The monthly statement is where you check that the disclosures held up. If yours shows one blended rate and a pile of unexplained charges, ask why, because the Code expects the totals to be broken out. Our guide to reading your merchant statement shows where each figure sits.

How much notice do you get before fees go up?

Thirty to 60 calendar days. Acquirers and the companies downstream of them must tell you within that window before a new fee or a fee increase takes effect, and the notice has to tell you about your right to leave (Code of Conduct).

The networks face a longer clock. The Code requires at least 120 calendar days' notice to acquirers for changes to domestic non-structural fees, so your processor often knows about a network change months before you do. It's worth asking, every so often, what's coming.

Renewals have their own rules under the Code. You have to give notice of non-renewal at least 45 days before your agreement renews, and a fixed-term agreement can only renew automatically in extensions of six months or less. Put the renewal date in your calendar the day you sign, minus 45 days.

When can you cancel without penalty?

When a fee goes up or a new fee is added, you can give notice that you're leaving your agreement without penalty, as long as you do it within 70 calendar days after the change takes effect. Older guides, written under the previous Code, mention 90 days from the notice. That's out of date.

Here's a worked timeline. Say a café in Halifax gets a notice on February 1, 2027, adding a $15 monthly "platform fee" and raising its processor markup by 0.10%, both effective March 15, 2027. That's 42 days of notice, inside the 30 to 60 day window. The 70-day exit clock starts on March 15 and runs to May 24, 2027.

DateWhat happens
February 1, 2027Notice arrives
March 15, 2027New fees take effect
May 24, 2027Last day to give notice of exit without penalty

Is the change worth leaving over? On $30,000 a month in card sales, 0.10% is $30 a month. Add the $15 fee and the café pays $45 more a month, or $540 a year. That's real money, and the café has more than three months from the notice to get competing quotes. Don't wait for the last week: switching takes time, and the window doesn't stretch because a new provider is slow.

Which cards and payment options can you choose?

More than you might expect. Under the Code, a merchant that accepts a network's credit cards isn't obligated to accept its debit cards, and the reverse is also true. You can also offer discounts for different payment methods, such as a lower price for paying with Interac Debit, which Interac says costs merchants around 10 cents a transaction (Interac).

Surcharges are a different matter. The right to add a credit card surcharge comes from Visa's and Mastercard's own rules, which have allowed it since October 6, 2022, capped at 2.4% or your cost of acceptance, whichever is lower (Visa Canada). Quebec prohibits any fee for paying by card (OPC), so a business in Quebec can use discounts but not surcharges. Our guide to credit card surcharges in Canada covers the details.

How does the Code handle co-badged debit cards and digital wallets?

It keeps competing debit networks apart, on the card and in the phone. Many Canadian debit cards carry Interac plus a second brand, such as Visa Debit or Debit Mastercard, and the Code sets rules for how those sit together:

  • Competing domestic debit applications from different networks must not be offered on the same debit card, with an exception for ABM transactions.
  • Co-badged debit cards must be equally branded, with logos the same size and on the same side.
  • In a digital wallet, non-competing co-badged debit applications must be provisioned and presented separately.

That last rule matters at your terminal. A customer may see their Interac Debit and their Visa Debit as two separate cards in their phone's wallet, and whichever one they pick decides which network carries the sale and which fee schedule you pay. Our guide to Visa Debit in Canada compares the two.

It also affects refunds. Visa's processing guide says that if a customer brings back an item bought online with Visa Debit to a physical store, the refund can't go through the Visa system because of restrictions under the Code (Visa Canada). If you sell online and in store, plan how you'll refund cross-channel returns before the first one walks in.

How do you file a complaint when a processor breaches the Code?

Start with the processor, in writing, and keep a copy. Under FCAC's complaint-handling guidance, payment card network operators, acquirers, and downstream participants must have a complaint process that is clear, simple, transparent, easy to access, and easy to understand (FCAC).

The deadlines are specific:

  1. Your processor has to acknowledge your complaint within 5 business days.
  2. It has to investigate and address it within 20 business days. For a payment card network operator, the limit is 30 business days.
  3. The answer comes in writing: an offer to resolve the complaint, or a denial with reasons.

You don't have to wait for that process to finish. FCAC says nothing in it stops a merchant from filing a complaint directly with FCAC at any stage. FCAC isn't a complaint resolution body, so it won't negotiate a refund for you, but it may open an investigation if your complaint suggests a network isn't meeting its Code obligations.

What doesn't the Code cover?

Rates. The Code governs disclosure, notice, and choice, but it doesn't set interchange or your processor's markup. The lower interchange for small businesses that took effect on October 19, 2024, came from separate commitments Visa and Mastercard made to the federal government, with eligibility below $300,000 in annual Visa sales and $175,000 in annual Mastercard sales (Finance Canada). Visa raises its small-merchant threshold to $750,000 in annual Visa volume on October 24, 2026 (Visa Canada).

It also won't fix:

  • A cancellation fee you agreed to for leaving early when no fee change was involved.
  • A terminal lease you signed separately with an unrelated company.
  • A pricing model you don't like. The Code requires fees to be disclosed; it doesn't choose how you're priced.

That last point is the big one. The Code makes sure you're told what you pay. It doesn't make sure the price is fair. On interchange-plus pricing, network rate cuts reach you automatically, which is why we price that way, with no long-term contracts and no cancellation fees. Our guide to credit card fees in Canada lists the current small-business rates.

A Code of Conduct checklist for merchants

  1. Find your information summary box, Cost per Transaction Disclosure, and Disclosure of Fees, and keep copies with your agreement.
  2. Check that your statement shows interchange, network fees, and other fees as separate totals at least monthly.
  3. Mark your renewal date, minus 45 days, in your calendar.
  4. When a fee notice arrives, write down the effective date and the date 70 days after it.
  5. Price out the change in dollars a year before you decide whether to stay.
  6. If you lease a terminal, confirm who the lease is with and whether it survives a processor switch.
  7. Decide which card types you want to accept, and whether a discount for debit makes sense.
  8. Put any complaint in writing, note the date, and escalate to FCAC if the deadlines pass.

Businesses from Toronto to Edmonton have the same rights, because the Code applies nationally. Our Canada hub covers the provincial rules that sit alongside it, and our merchant services page explains how we set up accounts.

Your next step

The Code gives you the paperwork. You still have to read it. Send us a recent statement for a free statement review, and we'll check it against your disclosures, separate the network costs from your processor's share, and say whether a recent fee change is worth acting on before your 70 days run out. If you'd rather talk first, book a consultation.

About this guide

Written by the Clearo Payments team. Clearo provides interchange-plus payment processing to merchants in the US and Canada, with no long-term contracts and no cancellation fees. Card network rules and laws change, so check the sources below before you act on anything here. Our editorial standards explain how we source and update guides. Questions about your own setup? Ask our team.

Common questions

Is the Code of Conduct for the Payment Card Industry a law?

Not a statute. It's a set of market conduct commitments that the major payment card networks in Canada have agreed to, and FCAC supervises their compliance. Companies that commit to it are obligated to follow it, and the obligations reach acquirers and the processors working under them.

How much notice must my processor give before raising fees?

Between 30 and 60 calendar days before a new or higher fee takes effect. The notice also has to tell you about your right to leave your agreement without penalty within 70 calendar days after the change takes effect.

Can I cancel my merchant agreement without penalty under the Code?

Yes, when a fee goes up or a new fee is added. You must give notice within 70 calendar days after the change takes effect. Older articles mention 90 days, which was the rule under the previous Code. Outside a fee change, your contract's own cancellation terms apply.

Does the Code let me add a surcharge to card payments?

No, surcharging comes from Visa's and Mastercard's own rules, which have allowed credit card surcharges since October 6, 2022, up to 2.4% or your cost of acceptance. The Code does let you offer discounts for different payment methods. Quebec prohibits fees for paying by card.

Where do I complain about a Code of Conduct violation?

Start with your processor in writing. It must acknowledge your complaint within 5 business days and address it within 20 business days. You can also file a complaint with FCAC at any stage. FCAC does not resolve individual disputes, but it may investigate whether a network is meeting its Code obligations.

Disclaimer: general information, not professional advice

This guide is general educational information, not legal, tax, accounting or financial advice. Rules and rates vary by place and change, so confirm them with the official source and a qualified professional before you act. Full terms are in our Terms of Service.

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