Reporting changes to registration information

Publication date: October 16, 2024

This supervisory policy explains how the Bank of Canada expects registered payment service providers (PSPs) to comply with requirements to provide updated registration information.

Introduction

Under the Retail Payment Activities Act (RPAA) and the Retail Payment Activities Regulations (RPAR), registered PSPs must inform the Bank when there are changes or anticipated changes to certain information that the PSP provided during the registration process. The timing requirements for informing the Bank of these changes varies depending on the nature of the information. There is no limit to the number of changes a PSP may submit.

Note that this process applies to PSPs once they have become registered. A separate process applies to applicants that undergo changes or learn of new information while their applications are under review. For that process, see the Bank’s supervisory policy on Amendments to registration applications.

Types of changes

Under sections 59 and 60 of the RPAA, registered PSPs must notify the Bank of changes to information that they initially provided to the Bank during the application process. Deadlines for such notifications depend on the nature of the information being updated. To determine the applicable deadline for a given change of information, please consult Appendix A.

Information that must be updated within 30 days of the day after the change has occurred includes items such as:

• general information, such as the business’s address and website
• details about the PSP’s retail payment activities, such as descriptions of their payment functions

Certain information needed for the Minister of Finance to review the national security implications of the PSP’s operations in Canada, such as information about its directors and major shareholders, must be updated as soon as feasible after the PSP becomes aware of the change. This means the PSP should:

• inform the Bank before the change occurs if the PSP becomes aware of the change in advance, or
• notify the Bank as soon as possible once the change has occurred if the PSP learns about the change after it has happened

Other information needed for the Minister of Finance to review the national security implications of the PSP’s operations in Canada must be updated at prescribed times (either 30 or 60 days) before the change occurs. Such information includes items such as:

• information about the personal and financial data that PSPs collect
• locations where the data are stored

Determining whether a significant change or new activity notice must also be submitted

Under section 22 of the RPAA, a PSP must also notify the Bank before making a significant change in the way it performs a retail payment activity or before performing a new retail payment activity as defined in the RPAA (for more information, see the supervisory guideline on significant change). A PSP reporting an information change under sections 59 or 60 of the RPAA must also consider whether the change is related to an underlying significant change or to the performance of a new retail payment activity.

For example, if a PSP plans to begin performing a new retail payment activity that it did not perform before, such as holding funds for end users, it would be correct to report this change of information to the Bank under section 59 of the RPAA. However, simply reporting the change in information would not meet all the requirements set out in the RPAA. As set out in section 22 of the RPAA, the PSP would also have to notify the Bank that it is performing a new retail payment activity, i.e., holding of funds on behalf of an end user. This notice, must be submitted separately from the change of information report, at least five days before the change occurs, and it should provide detailed information about the new retail payment activity and its impact on the PSP’s operational risks or safeguarding of end-user funds.

Appendix A identifies changes to information that must be reported under sections 59 and 60 of the RPAA, which may also be significant changes or new activities or result from significant changes or new activities under section 22 of the RPAA. Please consult the related footnotes of Appendix A for more details, as well as the supervisory guideline on significant change. It is each PSP’s responsibility to determine whether a change made, or a new activity performed, by the PSP is a significant change or new retail payment activity of which the Bank must also be notified under section 22 of the RPAA.

New applications following acquisition of control or other changes

Section 24 of the RPAA requires a registered PSP to submit a new application for registration, and become registered under the new application, before a different individual or entity acquires control of the PSP or before making certain changes prescribed in the regulations. For more information, see the supervisory policy on acquisitions of control and prescribed changes.

An acquisition of control or prescribed change that requires a new application under section 24 of the RPAA may also result in changes to information of which PSPs would ordinarily notify the Bank under section 59 or 60 of the RPAA. A PSP that submits a new application for registration is not required to also submit notices of changes in information under sections 59 and 60 of the RPAA through the process described above, provided that all relevant changes are reflected in its new application for registration.

Appendix A—Requirements for reporting changes to registration information

Each registered PSP is responsible for reporting changes to their registration information to the Bank within the applicable time period.

Based on the type of change, the section identifies the:

• sections of the RPAA or RPAR to which the changes apply
• required timeframe for reporting the change

In addition, this section identifies certain instances where changes reportable under section 59 or section 60 may intersect with other reporting obligations for PSPs. For changes to registration information, PSPs should determine whether the change could be considered a significant change or a new retail payment activity for which a notice is required under section 22 of the RPAA or related to an acquisition of control or prescribed change that requires the submission of a new registration application under section 24 of the RPAA. If so, the PSP must determine its corresponding reporting obligations.

Name ID and operating status

• Information required under:
• paragraph 29(1)(a) of the RPAA
• Notice of change in information reporting requirement:
  • section 59 of the RPAA
• Timing requirement:
  • 30 days after the change

Contact information

Contact information1

• Information required under:
  • paragraphs 29(1)(b)–(c) of the RPAA
  • subsection 24(2) of the RPAR
• Notice of change in information reporting requirement:
  • section 59 of the RPAA
• Timing requirement:
  • 30 days after the change

Business structure

Business structure2

• Information required under:
  • paragraph 29(1)(d) of the RPAA
  • subsection 24(3), paragraphs 24(9)(b)–(l) of the RPAR
• Notice of change in information reporting requirement:
  • section 59 of the RPAA for paragraph 29(1)(d) of the RPAA and subsection 24(3) of the RPAR
  • section 60 of the RPAA for paragraphs 24(9)(b)–(l) of the RPAR
• Timing requirement:
  • 30 days after the change
  • as soon as feasible after the PSP becomes aware of the change for paragraphs 24(9)(b)–(c), (e)–(l) of the RPAR
  • at least 30 days before the day on which the change takes effect for paragraph 24(9)(d) of the RPAR

Agents and mandataries

Agents and mandataries¹

• Information required under:
  • paragraph 29(1)(e) of the RPAA
  • subsection 24(4) of the RPAR
• Notice of change in information reporting requirement:
  • section 59 of the RPAA
• Timing requirement:
  • 30 days after the change

Values and volumes

Values and volumes¹

• Information required under:
  • paragraph 29(1)(f) of the RPAA
  • subsection 24(5) of the RPAR
• Notice of change in information reporting requirement:
  • section 59 of the RPAA
• Timing requirement:
  • 30 days after the change

Payment functions

Payment functions¹

• Information required under:
  • paragraph 29(1)(j) of the RPAA
  • subsection 24(7) of the RPAR
• Notice of change in information reporting requirement:
  • section 59 of the RPAA
• Timing requirement:
  • 30 days after the change

Third-party service providers

Third-party service providers¹

• Information required under:
  • paragraph 29(1)(k) of the RPAA
  • subsection 24(8) of the RPAR
• Notice of change in information reporting requirement:
  • section 59 of the RPAA
• Timing requirement:
  • 30 days after the change

Geographic perimeter

• Information required under:
  • paragraphs 29(1)(m),(o) of the RPAA
  • paragraph 24(9)(a) of the RPAR
• Notice of change in information reporting requirement:
  • section 59 of the RPAA for paragraphs 29(1)(m),(o) of the RPAA
  • section 60 of the RPAA for paragraph 24(9)(a) of the RPAR
• Timing requirement:
  • 30 days after the change for paragraphs 29(1)(m),(o) of the RPAA
  • as soon as feasible after the PSP becomes aware of the change for paragraph 24(9)(a) of the RPAR

Affiliated entities

• Information required under:
  • paragraph 24(9)(c) of the RPAR
• Notice of change in information reporting requirement:
  • section 60 of the RPAA
• Timing requirement:
• as soon as feasible after the PSP becomes aware of the change

Provincial and/or territorial registration

• Information required under:
  • paragraph 29(1)(n) of the RPAA
• Notice of change in information reporting requirement:
  • section 59 of the RPAA
• Timing requirement:
  • 30 days after the change

Personal and financial information

• Information required under:
  • paragraphs 24(9)(m)–(o) of the RPAR
• Notice of change in information reporting requirement:
  • section 60 of the RPAA
• Timing requirement:
  • at least 30 days before the day on which the change takes effect for paragraph 24(9)(m) of the RPAR
  • at least 60 days before the day on which the change takes effect for paragraph 24(9)(n) of the RPAR
  • as soon as feasible after the PSP becomes aware of the change for certain changes under paragraph 24(9)(o) of the RPAR and at least 30 days before the day on which the change takes effect for other changes under the same subsection

End users and interconnectedness

• Information required under:
  • subparagraphs 24(9)(p)(ii) and 24(9)(q)(ii) of the RPAR
• Notice of change in information reporting requirement:
  • section 60 of the RPAA
• Timing requirement:
  • as soon as feasible after the PSP becomes aware of the change