Financial Consumer Agency of Canada Releases Review of Banking Fees

On October 23, 2026, the Financial Consumer Agency of Canada (FCAC) published a Review of Banking Fees in Canada (Review), examining how banking fees are structured, disclosed and experienced by consumers. The Review was conducted in response to a request made by the Government of Canada in Budget 2025: Building Canada Strong (Budget 2025) that the FCAC prepare a report on the structure, level and transparency of fees charged by Canadian financial institutions. We previously discussed the government’s commitment to working with banks to bring more transparency to fees for sending money abroad in our prior bulletin, 2025 Federal Budget: Financial Sector Highlights and, most recently, in our bulletin on Budget 2026: Masters of our Destiny (Budget 2026), 2026 Federal Budget: Financial Sector Highlights.

The Review’s scope considers fees charged by domestic banks (Schedule I), foreign bank subsidiaries (Schedule II), federal credit unions and companies incorporated under the Trust and Loan Companies Act (collectively, Canadian FIs), and its findings apply to these entities. The Report focuses on common fees associated with personal deposit accounts and related services across nine major fee categories, including:

• Account maintenance fees
• Excess transaction fees
• ATM fees
• Non-sufficient funds (NSF) fees
• Overdraft protection fees
• Currency conversion mark-ups
• Cross-border debit fees
• Transfer-out fees
• Prepaid payment product fees

Notably, fees on credit products and business or commercial services are outside the scope of the Review. Specifically, by drawing on industry data, consumer research, international experience and engagement with financial service providers and regulators, the Review considers differences in fees for comparable products and services, how clearly fee information is communicated, and how consumers experience these fees in practice.

Based on its assessment, the FCAC sets out 22 findings relating to banking fees and identifies several themes that may warrant further policy consideration. The FCAC also considers international approaches to banking fees and the potential for consumer-driven banking to improve transparency and comparability and to facilitate switching between financial service providers. While the Review does not impose new obligations, these findings provide an indication of where future policy and regulatory expectations for Canadian FIs may be heading. This bulletin summarizes some of the main themes of an extensive and detailed examination conducted by the authors of the Review. Please consult the full Review for a more detailed discussion of the FCAC’s findings.

Key Findings

1. The True Cost of Banking and Transparency

A central theme of the Review is that the true cost of banking is cumulative. Taken together, the findings suggest that the cost of banking is shaped not only by the level of individual fees, but also by how fees interact, accumulate and are experienced by consumers over time. Fees can arise from many common banking activities, including maintaining and using an account, exceeding account transaction limits, using ATMs, having insufficient funds to cover a payment, overdraft protection and foreign currency transactions. As a result, a single transaction can potentially trigger more than one fee. What a given consumer pays therefore depends less on any one individual fee than on how fees interact and accumulate based on that consumer’s banking behaviour. While the Review does not specifically consider differential impacts of fees across consumer groups, it does note that certain consumers may be disproportionately affected by the cumulative costs of fees, particularly those with lower incomes, less savings or those who have a greater reliance on day-to-day banking services.

The FCAC also found that many consumers hold account plans that do not match their current banking activities. Some pay for higher-tier features they rarely use, while others incur fees because a lower-cost plan does not include services they rely on. Approximately 10% of consumers remain in legacy plans no longer offered to new customers, which generally carry higher fees, lower transaction limits and separate charges for services that newer plans commonly include.

Although individual fees are generally disclosed, consumers often cannot readily determine what they will pay for a particular transaction. When multiple fees are applied to a single transaction, consumers not only pay a higher cost, but the banking fees that apply can be difficult for consumers to see or expect. As a result, consumers may not know the total cost of some transactions before completing them. For example, several parties may each charge a fee on a single ATM withdrawal with no consolidated view of the total cost before the transaction is confirmed; currency conversion markups are embedded in the exchange rate rather than shown as a standalone cost and fee information for prepaid products may appear only in small print on packaging.

International approaches referenced by the FCAC, including the United States’ advance ATM fee disclosure, the United Kingdom’s prohibition on double charging at ATMs and the European Union’s requirements to disclose foreign exchange markups in advance, suggest the direction future Canadian expectations may take.

The Review suggests that the impact of cumulative banking costs could be addressed through enhanced transparency for fees, including fees associated with ATM transactions (where multiple parties may charge fees on the same transaction) and cross-border debit transaction fees, which are often embedded in exchange rates or overall transaction amounts.

2. Point-in-Time Versus Use-Based and Personalized Disclosures

Canadian FIs are already required under the Bank Act to disclose applicable fees in account agreements, provide periodic statements, send low-balance alerts and give advance notice of fee increases. However, this point-in-time approach does not give consumers a clear picture of what their accounts cost them over time based on their own usage. For example, excess transaction fees are typically assessed only at the end of the billing cycle, and consumers may struggle to track the total they pay in NSF and overdraft fees.

The FCAC highlights the need for personalized, usage-based disclosure as a way forward, including: (i) adapting existing alerts to notify consumers when they are nearing transaction limits or incurring excess transaction fees and (ii) a standardized statement, issued at least annually, summarizing cumulative fees paid. According to the Report, more personalized and usage-based information could help consumers better understand the fees they pay and support more informed decision-making, as well as provide consumers with the information they need to determine whether their current products continue to meet their needs.

In line with this finding, the Government of Canada announced in Budget 2026 its intention to develop regulations requiring Canadian FIs to provide consumers with a single clear annual statement of the fees paid on each chequing and savings account.

3. Switching and Competition

Transfer-out fees can discourage consumers from switching providers even when they have identified lower-cost or better-suited alternatives, weakening competitive pressure. The Report recognizes that consumers face both direct and indirect costs associated with switching providers. In particular, switching costs extend beyond fees, as consumers face the time and effort of moving accounts and updating direct deposits, bill payments and pre-authorized transactions. The FCAC suggests that measures to facilitate switching be considered alongside the implementation of consumer-driven banking, pointing to the U.K.’s Current Account Switching Service as an example.

Budget 2025 announced the government’s intention to prohibit certain transfer-out fees to help Canadians switch between financial service providers. Notably, on November 7, 2026, the Department of Finance published the proposed Regulations Amending the Financial Consumer Protection Framework Regulations (Investment Account Transfers), which would prohibit Canadian FIs from charging transfer fees for registered and investment accounts. While this prohibition does not apply to chequing and savings accounts, it indicates a willingness by the Government of Canada to promote competition by reducing or eliminating transfer costs.

What’s Next?

While the Review does not introduce new requirements, there is a clear message that bank fee structures are complex and can be difficult for consumers to understand, predict and compare, with implications for affordability and competition. The Report concludes that there are opportunities to improve consumer outcomes and competition, including by strengthening transparency, improving comparability and reducing barriers in order to empower consumers to make informed decisions. Consistent with its mandate, the FCAC has indicated that it will continue to monitor trends and emerging issues and contribute research and analysis to support evidence-based policy development. Nonetheless, its findings provide a basis for further examination of the structure, level and transparency of banking fees and may inform future policy discussions.

For more information, please contact any member of our Financial Services Regulatory group.