FCAC’s review of banking fees in Canada: Key implications for financial institutions

On October 23, 2026, the Financial Consumer Agency of Canada (“FCAC”) published its Review of Banking Fees in Canada (the “Review”), fulfilling a Budget 2025 commitment calling on the FCAC to report on the structure, level and transparency of fees charged by Canadian banks.

The Review identifies 22 findings regarding banking costs, fee disclosures, consumer choice and competition in Canada’s financial services industry.

Key takeaways

• Potential areas for future policy consideration. The Review identifies cumulative fee disclosures, transaction-related charges and account switching as themes for possible future policy attention. Although the Review does not itself create new regulatory requirements for banks and federal credit unions, some themes have already gained traction, including through the recently proposed regulations on investment account transfers and the Budget 2026 proposal to require a single annual statement of fees.
• Combined and cumulative costs are a focus. The Review examines both the disclosure of individual fees and charges, and consumers’ ability to understand their total costs over time and assess the value of banking products and services based on their actual usage.
• Transfers and relationship pricing have implications for both customer retention and acquisition. The Review examines transfer fees, bundled benefits and the administrative steps involved in changing providers. Clear explanations of relationship benefits, transfer costs and reimbursement conditions can support informed decisions by existing and prospective customers. The federal government has since published proposed Regulations Amending the Financial Consumer Protection Framework Regulations (Investment Account Transfers) that would generally prohibit banks from charging fees to close or transfer investment accounts, including registered accounts.
• Personalized information could complement existing disclosures. The FCAC identifies standardized annual fee summaries, usage-based account comparisons and transaction-limit alerts as potential enhancements. The Review does not create new obligations, however, the more recent Budget 2026 signals plans for regulations requiring banks to provide consumers with a single, clear annual statement of fees paid on their chequing and savings accounts.
• Consumer-driven banking could support comparison tools. Consumer-authorized financial data sharing could enable more personalized comparisons of account costs and features, although FCAC notes that practical switching barriers may still affect consumers’ ability to act on that information.

The Review draws on bank fee schedules, industry data, consumer research and international regulatory practices. The following sections discuss five principal themes emerging from the Review’s 22 findings.

Personalized fee disclosure

The Review considers how personalized, usage-based information could complement existing fee disclosures and help customers assess their overall banking costs. For banks, these findings highlight potential developments in customer communications and opportunities to explain how account features and pricing relate to individual usage patterns.

Banks and federal credit unions are already subject to disclosure requirements under the Bank Act and the Financial Consumer Protection Framework Regulations and certain provincial regulations, including requirements concerning applicable fees, periodic account statements, notices of certain changes and electronic low-balance alerts for personal deposit accounts.

The FCAC recognizes that existing disclosures already inform customers about applicable fees and individual charges. The Review explores how this information could be supplemented with a consolidated view of costs incurred over time and information that helps customers compare account options based on their actual usage. It identifies three potential enhancements:

• Standardized periodic fee statements. The FCAC states that requiring federally regulated deposit-taking institutions to provide consumers with a standardized statement, at least annually, summarizing the cumulative fees paid on their personal deposit accounts would strengthen transparency and comparability. Budget 2026 subsequently announced plans to develop regulations addressing annual banking fee statements, as discussed in our blog post, Budget 2026: Financial institutions update.
• Usage-based account comparisons. Information reflecting actual account usage could help consumers assess whether their existing account remains suitable for them, including through like-for-like comparisons and information on alternative accounts offered by the same provider, where available. Such comparisons could also help banks and federal credit unions explain the value of account features and included services, rather than focusing on monthly fees alone.
• Transaction-limit alerts. The FCAC identifies potential opportunities to adapt existing disclosure mechanisms, such as low-balance alerts, to notify consumers when they approach their transaction limits or incur excess transaction fees. The FCAC notes that such notifications could encourage consumers to reassess their account usage or consider alternative arrangements better suited to their needs.

The Review draws on approaches in other jurisdictions and sectors, including the European Union’s standardized annual statement of fees and Canadian investment-sector cost disclosure reforms.

Account selection and usage patterns

The FCAC’s findings highlight opportunities to help customers match account features to their usage. For instance, customers who complete fewer transactions may not need all the features of premium accounts while those with higher transaction volumes may benefit from plans with premium transaction allowances. These findings are relevant to how providers communicate account features, transaction allowances and available account options to existing and prospective customers.

The Review also discusses how transaction alerts could complement existing disclosures and aid consumers’ ability to monitor their account usage. Although excess transaction fees are disclosed in account agreements and fee schedules, banks and federal credit unions are not currently mandated to notify customers when they approach or exceed their monthly transaction limits. Because these fees are ordinarily assessed at the end of the billing cycle, providing timely alerts could give customers greater visibility into their usage and anticipate potential costs before they are incurred.

Legacy accounts present another opportunity for customer engagement. The FCAC reports that approximately 10% of consumers remain on monthly account plans that are no longer offered to new customers. These plans may have higher fees, lower transaction limits or separate charges for services, such as Interac e-Transfers, that are now commonly included in newer offerings. FCAC observes that, as consumers’ transaction patterns evolve, legacy account arrangements may no longer align with their needs.

Transaction fees: Customer understanding

The Review examines how consumers understand transaction-related fees, with a focus on the combined cost of individual transactions and charges accumulated over a period of time. For banks, the findings highlight opportunities to build on existing fee disclosure practices by helping customers understand how different charges apply to their use of banking services.

• Automated teller machine (“ATM”) fees. Withdrawals from ATMs operated by other financial institutions or independent operators may involve charges from more than one service provider. These can include a network access fee charged by the customer’s bank, a convenience fee charged by the ATM operator and an excess transaction fee under the customer’s account plan. While the ATM operator’s convenience fee is generally displayed on-screen, account-level charges are disclosed separately by the customer’s bank. The FCAC observes that this separation can make it difficult for customers to determine the combined cost of a withdrawal, particularly where access to lower-cost ATMs is limited.
• Non-sufficient funds (“NSF”) and overdraft protection fees. The FCAC finds that consumers may have difficulty assessing the cumulative cost of NSF and overdraft charges, even where individual fees are disclosed. The Review discusses the federal restrictions on NSF fees for personal deposit accounts that took effect in March 2026, including the $10 cap on NSF fees, restrictions on repeated fees within a two-business-day period and the prohibition on charging an NSF fee where the account shortfall is less than $10.
• Currency conversion. The Review examines how foreign exchange costs are communicated where a currency conversion markup is incorporated into the exchange rate rather than disclosed separately. The FCAC notes that a transfer with no service fee may nevertheless involve a currency conversion cost and that differences in markups can make comparisons among providers difficult.
• Cross-border debit fees. The FCAC observes that cross-border debit fees may be incorporated into the final amount of foreign debit purchases or ATM withdrawals rather than displayed separately. The Review notes variation in these fees among providers and identifies them as an area for further examination. Clear explanations of when these charges apply can help customers compare payment options before transacting abroad.
• Prepaid payment products. The Review highlights how the cost of prepaid payment products varies with customer usage, including ATM withdrawals, foreign-currency transactions and periods of inactivity. Purchase, maintenance and usage fees can reduce the available balance over time. The FCAC finds that fee information may not be sufficiently transparent, particularly where disclosures are not prominent at the point of purchase, limiting consumers' ability to understand applicable charges and compare products. The Review also notes that marketing may blur the distinction between prepaid payment products and gift cards, potentially creating confusion about applicable fees and restrictions.

Across these categories, the Review focuses on helping customers understand combined and cumulative costs.

Account transfers and relationship-based pricing

The Review examines how transfer costs, relationship-based pricing and the practical steps involved in moving accounts can influence consumer decisions to change financial service providers. For providers, these findings are relevant both to support existing customer relationships and to attract new customers.

For registered products, the Review reports that full account transfer-out fees generally range from $50 to $150 per account, while partial transfer fees range from $25 to $75 per request. Charges assessed per account can accumulate when customers transfer multiple accounts. The FCAC also notes that the impact may be greater for customers with smaller balances, particularly where reimbursement by the receiving institution is subject to minimum transfer amounts or other conditions. These findings highlight the value of clearly explaining applicable transfer fees and reimbursement conditions so customers can assess the costs of moving their accounts.

The Review also considers relationship-based pricing, through which banks or federal credit unions offer fee waivers, discounts or other benefits based on account balances or the number of products held with the institution. These arrangements can provide value to customers, however, the FCAC notes that bundled benefits may make comparisons with standalone products more complex, and that moving one product may affect benefits available on others.

For financial institutions, clear communication about the benefits of a broader banking relationship and the consequences of changing individual products can support informed customer decisions.

Beyond pricing, the Review also discusses real-world variables involved in switching providers, including transferring accounts, updating direct deposits and pre-authorized payment schedules, and establishing new banking arrangements.

The FCAC notes that more than half of Canadians have maintained their primary banking relationship with the same financial institution for 15 years or more. Assistance with these administrative steps may be relevant to customer acquisition and relationship development. The length of a banking relationship does not, on its own, establish that a consumer faces barriers to switching.

The FCAC considers that reducing switching barriers could strengthen competition among financial institutions. The proposed Regulations Amending the Financial Consumer Protection Framework Regulations (Investment Account Transfers) would also establish requirements relating to investment account transfer timelines and disclosures about the transfer process. The proposed fee prohibition would be subject to an exception permitting charges where a transfer or closure request is received less than 90 days after the account was first funded.

Consumer-driven banking

The Review also considers the potential role of Canada’s emerging consumer-driven banking framework in improving fee transparency, product comparability and competition.

The framework is intended to enable consumers to authorize the secure sharing of their financial data, including account balances and transaction histories, with participating service providers through standardized technology. The Review notes that Canada’s framework is being introduced in phases, beginning with read-only data sharing.

From a fees perspective, the FCAC considers that access to consumer-authorized financial data could support the development of personalized comparison tools. Rather than relying solely on publicly available fee details, these tools could analyze a consumer’s own transaction history and assess the total account maintenance, overdraft and transaction fees paid over a particular period. This information could also help consumers compare costs with alternative products or services offered by their existing providers or other financial institutions.

What’s next

The FCAC states that it will continue to monitor banking fee trends and emerging issues, conduct research to support evidence-based policy development, and draw on the Review to inform its consumer awareness and financial literacy initiatives.

While the Review does not introduce new regulatory requirements for banks and federal credit unions, it signals potential areas of future policy attention, including cumulative fee disclosures, transaction-related fee transparency and account switching.

For financial services providers, these themes offer a potentially useful framework for assessing their existing disclosure practices, product offerings and customer communications.

For more information about our firm’s financial institutions regulatory expertise, please see McCarthy Tétrault’s Financial Institutions Regulatory page.