RPAA Registration Canada — Bank of Canada PSP Support
Launching a payment platform, wallet or remittance service in Canada? We help determine whether Bank of Canada registration is required and prepare the information needed for a PSP Connect application.
We work with Canadian businesses and overseas PSPs serving Canadian end users, including marketplaces, processors and software companies offering payment services.
Who needs RPAA registration in Canada?
Start with the activities your business performs. These four checks help establish whether the Retail Payment Activities Act applies.
Do you perform a payment function as a service?
The RPAA names five payment functions, including transfer initiation, instruction handling and holding end-user funds. Check whether you provide any of them as a service.
Does it relate to an electronic funds transfer?
The activity must relate to an electronic funds transfer. Identify the transaction type and currency or unit involved; digital-asset-only arrangements require separate classification.
Does your business meet the Canadian geographic test?
A Canadian place of business may bring the service within scope. For a foreign PSP, assess whether it directs services at Canada and serves an end user physically in Canada.
Is an entity or activity exclusion available?
Check whether the specific entity or activity qualifies for an exclusion. Different services within the same group may not receive the same treatment.
Which payment activities can trigger PSP registration?
A single transaction can involve several regulated functions. Use these examples to work out which parts your business performs.
| Payment function | Practical example | Question to resolve |
|---|---|---|
| Providing or maintaining an account | An account used to save payment details or arrange future electronic transfers for an end user. | Does the account serve a payment function beyond a one-off checkout? |
| Holding end-user funds | A wallet balance or intermediary account where money is held for a payer or payee before onward transfer. | Who legally holds the funds, where, and for how long? |
| Initiating an electronic funds transfer | A platform initiating an electronic payment at a customer’s request. | Who sends the instruction that starts the transfer? |
| Authorizing transfers or handling payment instructions | A gateway, processor or interface authorizing a transfer or transmitting, receiving or facilitating related instructions. | Is your role only technical, or do you perform an RPAA payment function? |
| Clearing or settlement services | An intermediary that calculates obligations or settles payments between participating parties. | Do you clear or settle transactions for another entity? |
Online store selling its own products
A store taking payment for its own inventory differs from a business that processes payments for other merchants.
Marketplace paying third-party sellers
Seller payouts may involve the marketplace, a processor and a bank. Identify who performs each payment function under their agreements.
Remittance app or multi-currency wallet
Check whether balances are maintained, transfers initiated or payments settled through the app or a contracted provider.
RPAA exclusions, agents and foreign PSPs
An exclusion may apply to one activity but not another. The legal entity and the part of the payment service it performs both matter.
Activities and entities to examine
- Incidental payment functions used only to support another business activity.
- Merchant instruments and qualifying closed-loop arrangements.
- Internal transfers between affiliates and specific securities-related activities.
- Cash withdrawal through ATMs and other expressly excluded activity categories.
- Banks and certain other excluded financial institutions.
Agents, vendors and foreign PSPs
An agent acting for a registered PSP may qualify for an exclusion in the relevant circumstances. A technology supplier or affiliate is not automatically covered by that exclusion.
Foreign PSPs should retain a clear description of which services are offered to people in Canada and which entity contracts with those customers.
Where a partner is described as the payment provider, verify that the contract supports that division of responsibility.
FINTRAC MSB registration vs RPAA registration
FINTRAC and the Bank of Canada regulate different activities. A remittance or fintech business may need to assess both registration regimes.
FINTRAC / MSB
Focuses on money services business registration and applicable anti-money-laundering and anti-terrorist-financing duties, such as reporting, recordkeeping, client identification and compliance programs.
FINTRAC MSB registration support →Bank of Canada / RPAA
Focuses on prescribed retail payment functions, payment-service-provider registration, operational risk, incident response and safeguarding end-user funds where applicable.
Prepare a PSP application →Your FINTRAC records can help identify the business and services, but the RPAA application also needs a separate description of payment functions, Canadian connections and funds-handling arrangements.
Bank of Canada PSP registration requirements and documents
PSP Connect requires details about the applicant, payment services, activity levels and relevant controls. This checklist helps your team locate the information before completing the form.
| Application area | Information to prepare | How we can help |
|---|---|---|
| Entity, ownership and governance | Legal and trade names, directors, ownership and debt holders, controlling individuals, business structure and key contacts. | Check that the applicant named in the forms matches its corporate records and payment-service agreements. |
| Payment functions and funds flow | The services offered, each payment function performed, the parties involved and the path of funds and instructions. | Use a transaction diagram to show who sends instructions, who handles settlement and where end-user funds are held. |
| Scale and geography | Actual or projected payment and end-user volumes, values of end-user funds held, jurisdictions and Canadian connections. | Show how projections were calculated, including assumptions for launch-stage products. |
| Third parties, agents and affiliates | Providers, agents or mandataries and related entities involved in relevant functions. | Identify the legal role of each provider using the actual contracts and delegated responsibilities. |
| Operational risk and incident response | Whether the organization has or plans to establish a framework, with a clear description of its approach. | Describe incident escalation roles, critical suppliers and the systems on which payment availability depends. |
| Safeguarding end-user funds | The method used or proposed where the PSP holds end-user funds. | Match the fund-holder named in agreements to the proposed safeguarding and reconciliation arrangements. |
| Other regulatory registrations | FINTRAC registration or other relevant federal, provincial and territorial registrations. | Reference existing registrations without implying they replace a separate RPAA filing. |
The exact information requested depends on the applicant and services. Use the table to prepare relevant records before opening the form.
If a banking agreement identifies a partner as holding customer funds, the application should not describe your company as the fund holder without an explanation. Resolve that mismatch before filing.
How we help with your PSP Connect application
Trace a typical payment
We follow a payment from the customer instruction through processing, any funds held and the final payout. This identifies the entities and agreements that need closer examination.
Record the applicability position
We document relevant functions, the Canadian connection and potential exclusions, including issues that depend on contracts or operational facts.
Assemble PSP Connect information
We collect the corporate, ownership, transaction and safeguarding details needed for the application, with supporting calculations where estimates are used.
Check the filing before submission
Names, forecasts, payment-flow descriptions and third-party roles are checked for conflicting answers before the applicant submits its information.
Manage follow-up and handover
We help organize responses to Bank of Canada questions within the agreed scope and identify the compliance tasks the PSP will need to own.
After registration: risk, safeguarding and reporting
Registration is followed by operational duties. The responsibilities below need named owners and working procedures, not just policies filed with the application.
Operational risk & incident response
Document critical payment systems, people and vendors, identify risks, set preventive and recovery controls, and establish how material incidents are assessed and reported.
Safeguarding end-user funds
If funds are held for end users, assess the permitted safeguarding approach, supporting account and insurance/guarantee arrangements, reconciliation and insolvency procedures.
Regulatory reporting & changes
Registered PSPs have an annual-report deadline of March 31 following the reporting year. Material incidents and significant changes can trigger separate notices on different timelines.
Assign people to classify and escalate incidents, maintain the reporting calendar and reconcile safeguarded funds where applicable. We can assess readiness as a separate engagement after the application work.
RPAA registration fee and processing time in Canada
Plan separately for the filing fee, application preparation and the Bank’s review period. A submitted application is not the same as a registration decision.
Bank of Canada application fee
The Bank’s August 2026 FAQ lists a non-refundable $2,500 application fee. Confirm the amount payable in PSP Connect, as the fee policy provides for annual adjustments.
Our preparation fee is quoted separately after we assess the services and documents involved.
When can a new PSP begin operating?
A new in-scope PSP applying on or after September 8, 2025 must be registered with the Bank before starting retail payment activities. The earlier transition arrangement is not a route for new applicants.
The Bank may request more information and carry out national-security screening, so the review period depends on the application and the checks involved.
Questions about PSP registration
Answers to questions that often come up while preparing a PSP Connect application.
Can we prepare an RPAA application before our payment service launches?
Yes. For a proposed payment service, describe the planned functions and arrangements rather than presenting forecasts as operating history. Confirm the applicable registration requirements before beginning in-scope activity.
Can our consultant help us work in PSP Connect?
An applicant can give an authorized user access to assist with the application and respond to information requests. The applicant is still responsible for what is submitted.
How do we provide transaction estimates if the PSP is pre-revenue?
Use documented assumptions such as expected customer numbers, transaction frequency and average payment values. Keep the calculation basis so figures can be explained if the Bank asks for clarification.
Can one PSP registration cover several subsidiaries?
A corporate group is not automatically treated as one payment service provider. Each legal entity performing payment functions should be assessed to determine whether it needs its own registration.
What if our business changes while the application is being reviewed?
A new payment feature, partner or ownership arrangement may affect information already submitted. Identify the change and check the Bank’s instructions for updating the application rather than assuming the original description still applies.
What happens when the Bank asks for additional application information?
Review the exact question, identify the supporting records and prepare a consistent response. We can help coordinate that work, including revised payment diagrams, transaction assumptions or entity documents as needed.
Request a PSP registration scope and quote.
Send a short description of your payment service and current registration stage. We can discuss the work involved and provide a scope and fee for the assistance you need.
- Registration eligibility assessment
- PSP Connect application preparation
- Payment-flow and third-party documentation
- Post-registration compliance planning
For your first message, please do not include customer records, ID documents, bank statements or account credentials.