FINTRAC applies to dealers who lease or finance in-house, and in a more indirect way, to all dealers who deal with lessors and third party finance.

Effective April 1, 2025 all dealers who finance or lease passenger class vehicles (or other vehicles valued over $100,000) are expected to report to FINTRAC, although enforcement will not begin until 2026.

A financing or leasing entity is a person or entity that is engaged in the business of financing or leasing.

A financing or leasing entity is subject to the Act and associated Regulations when they engage in the financing or leasing of:

• property for business purposes, other than real property or immovables
• property valued at $100,000 or more, other than real property or immovables
• passenger vehicles in Canada

A passenger vehicle is a motor vehicle – other than an ambulance, a hearse, a motor vehicle that is clearly marked for policing activities, a motor vehicle that is clearly marked and equipped for emergency medical response activities or emergency fire response activities or a utility truck – that is designed or adapted primarily to carry no more than 10 individuals on highways and streets.

Enforcement

Enforcement gets real in 2026, so it’s very important for affected dealers to get up to speed on all of this.

The UCDA has provided useful links to guidance and training at: https://www.ucda.org/fintrac/

UCDA / KPMG Training

With respect to training, the UCDA is working with KPMG to design and make deliverable a webinar, template and the opportunity for one on one UCDA special-priced training geared towards small and medium sized dealers, as well as larger operators.

We hope to have this ready for January 2026 and there will be more details to follow.