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On July 16, 2024, then-Industry Minister François-Philippe Champagne asked Canada’s independent Competition Bureau to consider whether mobile-platform companies were limiting competition in digital wallets. The request focused on Apple’s control of iPhone functions used for contactless payments, including near-field communication (NFC).
It was a request to examine a potential competition issue—not an order to open an investigation, a finding that Apple or another company broke Canadian law, or a Canadian version of the European Union’s remedy.
What Champagne asked the Competition Bureau to do
Champagne wrote to the Competition Bureau after regulators and courts in other jurisdictions scrutinized Apple and rival digital-wallet providers. He said competition in digital wallets should be on the Bureau’s radar and expressed confidence that it would act if evidence showed anti-competitive conduct. Canadian Press reporting carried by CityNews described the letter and its international context.
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The wording matters because the Bureau is independent. A minister can draw attention to a possible problem, but cannot turn a letter into a legal finding. These are separate steps:
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- Ministerial request: The government asks the Bureau to consider an issue.
- Preliminary inquiry or investigation: Bureau officials gather evidence and assess whether the Competition Act may apply.
- Finding or legal proceeding: The Bureau may seek a remedy, bring an application before the Competition Tribunal or courts, or close the matter.
- Remedy: Any access requirement, settlement or court order would follow a separate process.
The sources available for this article do not establish that the Bureau opened a dedicated digital-wallet investigation as a result of Champagne’s letter. It is therefore inaccurate to say that Canada “opened an antitrust probe” or that Apple was found to have violated Canadian law.
What counts as a digital wallet?
“Digital wallet” covers several products that do not compete in exactly the same way:
- Device wallets: Apple Pay and Apple Wallet, Google Pay or Google Wallet, and Samsung Wallet store payment credentials on a phone or wearable and can be used at a contactless terminal.
- Online and peer-to-peer wallets: PayPal and similar services facilitate online purchases, transfers or stored credentials.
- Bank and fintech wallets: Financial institutions and payment companies may provide their own apps.
- Closed-loop wallets: A retailer or platform may control more of the payment relationship and the movement of funds.
- Tokenized card wallets: The wallet substitutes a device-specific token for the underlying card number.
The Canadian episode was mainly about mobile, contactless wallets—especially whether a rival can use NFC and other iPhone capabilities—not every online wallet.
The Competition Bureau has previously described mobile wallets as applications that let people pay at physical points of sale from a mobile device. It has also highlighted the importance of access to payment infrastructure and the ability of new providers to reach users on both sides of a payments network. See the Bureau’s financial-services technology consultation.
Why NFC and the phone operating system matter
NFC is short-range wireless technology. When a shopper taps a compatible phone or watch on a payment terminal, NFC enables the device and terminal to communicate.
The competitive question is broader than whether Apple, Google or Samsung offers a wallet. The company that controls the phone and operating system may also control:
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- access to the NFC chip and secure hardware;
- the default-wallet setting and the prompts shown at checkout;
- biometric authentication;
- secure-element and tokenization functions;
- application programming interfaces (APIs) available to third parties;
- app-store distribution, certification and technical terms; and
- how easily a user can switch wallets.
A platform owner can argue that centralized access protects privacy, prevents fraud and keeps the device reliable. A competition authority would have to test whether those reasons are genuine and proportionate, whether rivals receive equivalent capabilities and whether the same standards apply to the platform’s own wallet. The CityNews account identified NFC as the technology used to communicate with merchant terminals.
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A tap-to-pay transaction typically involves several layers:
Phone and operating system → wallet app → bank or card issuer → Visa, Mastercard or Interac → merchant acquirer and processor → merchant terminal.
That structure means Apple Pay, Google Wallet and Samsung Wallet are not interchangeable with Interac, a bank, a card network or a payment processor. Interac told a House of Commons committee that Canadians could access its products through Apple Pay, Google Pay and Samsung Pay. The committee record is available in this House of Commons evidence.
The relevant companies include Apple, Google and Samsung as device-platform operators; banks and card issuers; Visa, Mastercard and Interac; PayPal and other wallet providers; payment processors; merchants; and consumers. A bottleneck at one layer may persist even when competition exists at another.
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What the Bureau could examine
Champagne’s request did not identify proven misconduct. If the Bureau examined the issue, possible theories could include:
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- Refusal or limitation of access: A platform denies rival wallets NFC or other functions while reserving equivalent access for its own service.
- Self-preferencing: The platform makes its wallet the default, gives it deeper system integration or steers users through design.
- Technical or contractual discrimination: Rivals receive slower, narrower or more expensive access, or face conditions the platform does not impose on itself.
- Tying and ecosystem leverage: Access to authentication, app distribution or other phone services is linked to use of the platform’s wallet.
- Data advantages: Wallet usage gives the platform information or behavioral advantages that competitors cannot match.
- Switching barriers: Users cannot easily change defaults, move cards or retain passes, rewards and other credentials.
- Merchant and payment effects: Reduced wallet competition could weaken pressure on fees, payment choices or new lower-cost methods.
The Bureau has previously noted that mobile wallets using major card networks can affect incentives around payment acceptance fees and merchant choice in its submission on national payment-system oversight.
Why market definition and security claims matter
Competition analysis depends heavily on how a market is defined. “All payments” is a much wider market than “NFC wallets on a particular mobile operating system.” The relevant analysis could involve mobile operating systems, smartphone hardware, app stores, card networks, merchant acquiring and consumer payment applications at the same time.
Platform operators may say unrestricted access to NFC, secure elements or biometric systems would increase fraud and privacy risks. Those concerns are not automatically decisive, but they are relevant. A regulator would likely ask:
- Is the restriction technically necessary?
- Could vetted APIs, certification or sandboxing address the risk?
- Do rival wallets receive equivalent technical capabilities?
- Are fees and conditions objectively justified?
- Does the platform apply the same security requirements to its own wallet?
Even where several wallets are technically available, competition may remain weak if one is preinstalled or set as the default, users must re-enter cards manually, transit or identity credentials work only in one wallet, or banks support one service but not another.
Canada’s legal and institutional setting
The Competition Bureau administers and enforces the Competition Act, reviews mergers, investigates alleged anti-competitive conduct and advocates for competitive rules. Being large or successful is not, by itself, unlawful. An abuse-of-dominance analysis generally considers whether a firm has substantial market power, what the relevant market is, whether the conduct is an anti-competitive act and whether competition has been substantially prevented or lessened. Legitimate business justifications and efficiencies can also matter.
The Bureau’s earlier position statement about an Apple investigation illustrates why an inquiry should not be treated as a finding of illegality. The outcome of any future wallet assessment would depend on the evidence and the specific conduct examined.
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How the foreign developments influenced Ottawa
European Union
In 2024, the European Commission accepted commitments from Apple intended to let rival wallet and payment-service providers access relevant iPhone contactless-payment functionality in the European Economic Area. Those commitments are an EU remedy; they do not automatically apply in Canada.
United States
The U.S. Department of Justice sued Apple in March 2024. Its complaint alleged, among other theories, that Apple restricted access to iPhone hardware and software features that could support competing payment and wallet services. Allegations in a complaint are not proof.
United Kingdom
U.K. regulators said they would examine digital-wallet competition and consumer issues, citing services such as Apple Pay, Google Pay and PayPal. The legal tests, market definitions and remedies in those jurisdictions differ from Canada’s.
What happened afterward?
Champagne’s intervention was reported in July 2024. The reviewed sources do not verify a dedicated Canadian Competition Bureau case arising from it. The Bureau has continued broader work involving financial services, payments, data portability and related infrastructure.
That work should not be confused with a separate Bureau examination of Interac e-transfer pricing that began in 2024 after concerns raised by a House of Commons committee. According to the Bureau’s March 2026 remarks, Interac moved to a flat-fee e-transfer model in November 2025. That was a different matter from mobile-wallet access; the Bureau’s account is on Canada.ca.
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If access rules were opened, consumers might gain more wallet choice, easier switching and potentially stronger pressure for innovation or lower payment costs. Banks, fintechs and payment providers could have more opportunities to build services for phones people already own. Merchants could benefit if competing payment methods improve negotiating pressure.
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There are trade-offs. Poorly designed interoperability could create security, privacy, fraud or reliability problems. The policy challenge is not simply “open everything” or “protect the platform.” It is to determine whether restrictions are necessary, transparent, proportionate and available to rivals on fair terms, with independent oversight and a practical way to challenge them.
Frequently Asked Questions
Did Canada order an investigation into Apple’s digital wallet?
No. Champagne asked the independent Competition Bureau to consider the competition issue. The request was not a binding order, and the available sources do not verify that it produced a dedicated Canadian digital-wallet investigation.
Is Apple Pay the same as Interac?
No. Apple Pay is a device wallet and user interface. Interac is a Canadian payments network whose products can be used through wallets, along with cards, banks, processors and merchant terminals.
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The Bottom Line
Champagne raised a legitimate competition-policy question in July 2024: can a phone-platform owner control the NFC, defaults and security functions that rivals need to compete with its wallet? But the letter was not proof of wrongdoing, did not command a Bureau investigation and did not change Canadian law. Any Canadian remedy would require an independent, evidence-based Competition Act process.
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