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August 26th, 2025
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Guide: PSP Registration with Bank of Canada (RPAA)
Payments Regulation | Jul 30, 2024
Image: Pixabay/geralt
Do I Need to Register as a Payment Service Provider (PSP) with the Bank of Canada under the New Retail Payment Activities Act?
The Retail Payment Activities Act (RPAA) requires Payment Service Providers (PSPs) in Canada to register with the Bank of Canada. This article goes over the basic criteria, FAQs, case scenarios, and the registration process, and includes various useful links and resources.
Retail Payments Registration Criteria (more)
- Based on your payment services or function --> PSPs must register if they perform critical payment operations such financial transfers, account maintenance, or payment processing.
- Operate in Canadian Markets --> Registration is necessary for any PSPs operating in Canada or targeting Canadian clients.
- Some exemptions --> Certain organizations, such as government agencies and certain merchant programs, may be excluded.
Frequently Asked Questions (in detail)
Do I need a license?
- The RPAA requires registration, not licensing. The Bank of Canada maintains a list of registered PSPs. See the supervisory framework and registration requirements.
What if I'm operating now but not registered?
- During the transition period from November 1, 2024 – September 7, 2025, PSPs must apply for registration within 15 days of starting operations.
- After September 7, 2025, registration is required before executing any retail payment operations.
Are there any benefits of registration?
- Registration increases market confidence, promotes competition, and may provide access to essential payment systems.
See: Bank of Canada Publishes New Retail Payment Enforcement Policies
What is the scope of the RPAA?
- The RPAA applies to all PSPs engaged in retail payment activities in Canada, including international PSPs serving Canadian users.
Do cross-border transactions need to be reported?
- PSPs must record cross-border transactions, unless they are ancillary to other services. The Bank of Canada will offer guidance on reportable transactions.
Are there any exemptions?
- Banks and other financial institutions regulated under different Canadian laws may be excluded from the RPAA's requirements.
Registration Case Scenarios (more)
- Affiliated entities linked by control or ownership must register if they provide payment services.
- Agents who act on behalf of another entity must register if they make payments.
- Designated payment systems of the financial system.
- Foreign firms providing payment services in Canada must register.
- Merchants or group of merchants that issue store-specific payment instruments may be exempt from registration.
- Merchants who provide incidental payment services may need to register.
- Software providers who offer payment accounting software and invoice payment services.
- Providers of POS systems that process payment information must evaluate whether registration is required.
Registration Process
- PSPs must provide detailed information about their services and third-party relationships. See guide in preparing for registration application.
- A $2,500 non-refundable fee is required for registration.
- Applications filed during the transition period will be processed beginning September 8, 2025. Registration does not expire, although it can be withdrawn under certain circumstances.
See: BoC Speech: Essence of the New Retail Payment Activities Act
Conclusion
Registration as a PSP under the RPAA is required for compliance and market participation in Canada. See the Bank of Canada's FAQ page for more information.
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