Consumer Protection / Loyalty Programs

Almost all retail brands, franchised and non-franchised alike, offer some sort of loyalty points program. Loyalty programs have recently been the subject of legislative scrutiny, as media coverage has highlighted consumer concerns with the expiry of loyalty points. 


The Protecting Rewards Points Act passed in December 2017 and was retroactive to October 1, 2016. As of January 1, 2018 new regulations pertaining to reward points took effect. A key feature of the regulations is a ban on the expiry of loyalty points based on time alone, which means that points can still expire because of the passage of time, but there also must be a second reason (such as a combination of time passing and inactivity).


On May 2, 2017, the Québec government introduced new legislation intended to modernize the Quebec Consumer Protection Act (CPA), as well as provide for new consumer protection measures. Bill 134 was passed on November 15, 2017.

Draft regulations were published on April 18, 2018 with comments due by June 1, 2018. CMA undertook consultations with a variety of members for its submission and will provide updates about the final regulations as they become available.