Gift cards and loyalty programs

Things to know

With limited exceptions, gift cards cannot have an expiration date, and consumers cannot be charged usage, dormancy or other fees.
- Key exceptions to the prohibition on expiration dates include gift cards issued for promotional purposes (e.g., the consumer did not pay for the gift card), or issued for a specific good or service.
Any restrictions, limitations and conditions must be printed on the card.
Some provinces require the issuer to provide a cash refund of an unused balance on the gift card in certain circumstances.
The term “gift card” is defined broadly in provincial consumer-protection legislation, and includes physical and electronic gift cards, certificates, vouchers, and other devices.
Certain provinces also regulate points earned pursuant to loyalty programs, and also impose limitations on the ability of the issuer to expire the reward points.
- The term “points” is defined broadly to prevent circumvention of the legislation.
- Similar to the gift card legislation, there are certain exceptions from the prohibition on the expiration of points, including points issued for a specific good or service.

Ensure that you fully disclose any permissible usage limitations and fees to the consumer prior to purchase.
Ensure that your gift card provides all disclosure required by the gift-card legislation.
Refrain from having your gift card expire unless an exemption applies.

Download topic