Federal Government Seeks Consultations On The National Anti-Fraud Strategy Framework That Focuses On Banking, Telecommunications, And Digital Services Sectors

Building on Budget 2025, the federal government announced on March 30, 2026 that it is launching consultations on the National Anti-Fraud Strategy (the "Strategy"), which "aims to establish a robust, multi-sector approach through combatting fraud throughout its entire lifecycle."

The consultations are seeking feedback on three "initial measures":

• Supporting law enforcement's ability to combat fraud;
• Strengthening public awareness; and
• Establishing a "Multi-Sector Anti-Fraud Framework" (the "Framework").

The initial focus of the Strategy is on fraud that targets individual Canadians and small organizations, however, the proposed Framework would also "introduce new and enhanced obligations for federally regulated financial institutions, telecommunications service providers and digital platforms." These organizations may be required to, among other obligations, provide specific warnings to customers about fraud risks through large-scale payments, block or flag "spoofing" calls, implement screening for fraudulent profiles and pages, and block malicious adds.

Confirmed commitment to combatting fraud

The National Anti-Fraud Strategy Discussion Paper (the "Discussion Paper"), released concurrently with the March 30 announcement, confirms the government recognizes the growing scale and sophistication of fraud in Canada and its corresponding threat to Canadians and the Canadian economy. Losses to Canadians since 2022 exceed $2.4 billion, with the true impact "likely far higher."

The Discussion Paper raises concerns about the extent to which fraud in Canada spans multiple sectors, is perpetrated abroad or remotely, and increasingly uses artificial intelligence, sophisticated technology, and government-issued identifiers to carry out schemes.

Increased scrutiny of regulated organizations to prevent, detect and disrupt fraud

The Discussion Paper indicates the government is contemplating new "market-conduct requirements" for "regulated organizations to take measures to prevent, detect and disrupt fraud perpetrated against Canadians and to respond when fraud occurs, ensuring that Canadians do not bear liability when regulated organizations fail to fulfill obligations." The multi-sector approach has been proposed in response to a perceived piece-meal approach already in the marketplace to protect Canadians from fraud, such as Canada's anti-spam legislation.

The Strategy is currently aimed at certain market participants and enhancing pre-existing obligations in respect of those participants.

Targeted market participants

• Banks: The Discussion Paper describes amendments to the Bank Act in Bill C-15: An Act to implement certain provisions of the budget tabled in Parliament on November 4, 2025 as a "first step"to strengthen fraud-related consumer protections. These amendments would require banks to have policies and procedures to detect fraud and mitigate impacts for consumers, among other obligations. The Discussion Paper states that the government is in the process of developing further "fraud-related obligations for banks", and that the Financial Consumer Agency of Canada ("FCAC") would be responsible for monitoring and enforcing compliance.
• Telecommunications services providers: The Discussion Paper proposes the inclusion of telecommunications services providers (wire, radio, cable, optical or other electromagnetic systems), including those regulated by the CRTC, among the targeted market participants.
• Digital platforms: Recognizing the absence of legislated obligations on social media platforms, the Discussion Paper raises concerns with platforms profiting from fake activities, as well as failing to prevent, detect and remove fraudulent posts and ads. The Discussion Paper also proposes including instant messaging services and search engines as part of the scope of regulation.

The consultation seeks feedback on whether these sectors are appropriate for the initial Framework and whether others should be considered.

Proposed obligations

The Discussion Paper proposes that the Framework could be aimed at supplementing rather than duplicating existing fraud-related consumer protection measures already in place. The Discussion Paper organizes the proposed obligations into four main categories:

• Prevention: Design, operate and govern services in a way that reduces the likelihood that fraud can occur (i.e., anti-fraud governance, training programs, KYC requirements), putting the onus on organizations to educate their clients about fraud, and establishing reporting and complaint mechanisms for fraud including if the provider has not upheld its obligations;
• Detection: Ensure that organizations are effectively identifying fraud, which may include a requirement to internally investigate fraud and potentially requiring organizations to share fraud-related information with each other;
• Disruption: Disrupt fraudulent activity and prevent losses, including by removing a fraudster's access to services and warning users of fraud risks;
• Response: Allow individuals access to fraud information, transparent internal dispute resolution processes, and the ability to escalate complaints to an external body, including with potential compensation obligations where there is non-compliance with the Framework.

The Discussion Paper seeks feedback on these four main areas, as well as whether and how specific recommendations in each category should be implemented. It also seeks feedback on whether organizations should be held liable and what standards should apply in determining liability.

Central regulator

The Discussion Paper discusses how the Framework would likely need to be overseen and enforced by a "central regulator" with sector specific rules enforced by industry regulators with knowledge and expertise. These regulators could share information with each other and potentially law enforcement, the Discussion Paper proposes.

The Discussion Paper does not suggest that the nascent Financial Crimes Agency ("FCA") would be the central regulator and states that feedback is not being sought on the establishment of the FCA. The FCA was the subject of our previous post. In February and March 2026, the government issued news releases repeating its commitment for the new FCA to be created by Spring 2026. These comments in the Discussion Paper suggest that, as expected, the FCA will focus on criminal enforcement, rather than regulation.

Takeaways

The federal government continues to focus on fraud prevention and build momentum with the Strategy, signaling increased regulatory and enforcement efforts:

1. Fraud remains a central priority in this federal government's agenda, with a renewed focus on private market participants taking more responsibility in combatting fraud.
2. Banking, telecommunications, and digital services sectors may be required to commit to extensive anti-fraud changes in their organizations in order to comply with a multi-sector cooperative Framework, although no sector has been excluded yet from the initial aspect of the Strategy.
3. Organizations could face increased liability for any failure to comply with the new Framework, although the scope of any proposed liability remains subject to consultation and feedback.

Organizations in the financial services, telecommunications, and digital services sectors should be closely monitoring these developments and their impact on their operations in Canada and abroad. Interested stakeholders are required to provide their responses by April 28, 2026.

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