Supervisory framework: Registration

Learn about the registration requirements under the Retail Payment Activities Act and what will be expected of payment service providers.

Payment service providers (PSPs) must apply for registration with us when the Retail Payment Activities Act (RPAA) and the regulations come into force to continue providing their services. The Department of Finance Canada published the regulations in Part II of the Canada Gazette on November 22, 2023 to clarify details of the RPAA.

Who is subject to the Retail Payment Activities Act

Individuals or entities who meet all four of the following criteria must register with us by submitting an application and paying a registration fee.

Be a payment service provider

• Perform one or more payment functions that are not incidental to another service or business activity

Perform a retail payment activity

• Perform payment functions related to an electronic funds transfer made in Canadian or foreign currencies (excluding digital currencies)

Meet certain geographic scope

• Have a place of business in Canada regardless of where their end users are or where they direct their services
• Have a place of business outside of Canada but perform retail payment activities for an end user in Canada and direct retail payment activities at individuals or entities in Canada

Perform payment functions that are not excluded from the RPAA and associated regulations

• Individuals and entities excluded under the RPAA include:
  • banks and authorized foreign banks (pursuant to the Bank Act)
  • credit unions, insurance companies, and trust and loan companies
  • agents and mandataries of PSPs
  • Payments Canada
  • the Society for Worldwide Interbank Financial Telecommunication (SWIFT)
• Activities excluded under the RPAA include:
  • transactions using automatic banking machines
  • internal transactions among affiliated entities
  • securities transactions performed by an individual or entity that is regulated or exempted from regulation under Canadian securities legislation

Process for registration

We are developing a web application (PSP Connect) for applicants and registered PSPs. Among other activities, applicants and registered PSPs will be required to use PSP Connect to:

• submit their registration information
• keep their information up to date
• pay the registration fee
• comply with the reporting requirements under the RPAA

When to apply for registration

The RPAA includes a transition period to allow individuals and entities to apply for registration, and for us to review the applications. Individuals and entities will have 15 calendar days from the start of the transition period to apply for registration with us, and we will have 10 months to assess applications.

The 15-day period to complete the registration application applies to all individuals and entities that are subject to the RPAA. We will not grant any extensions.

During the transition period, individuals and entities who wish to start operating as a PSP after the 15-day application window but have not applied within that time must submit their registration application at least 60 days before they plan to start conducting retail payment activities.

Under the RPAA, we cannot inform an applicant about the outcome of their application during the transition period unless the Minister of Finance issues a directive to the Bank to refuse to register an applicant.

We will publish and maintain a list of all applicants on our website during the transition period. The list will include the following information as provided by the applicants:

• all legal and trade names
• the business address, telephone number and email address
• any website address

Operating during the transition period

Individuals or entities that currently provide retail payment services can continue to provide these services during the transition period, but only if they have submitted an application.

PSPs that operate during the transition period without having submitted their application may contravene section 104 of the RPAA. This is a serious violation and could result in the issuance of a notice of violation (NOV) that may be accompanied by a substantial administrative monetary penalty.

Information about NOVs will be published on our website including the name of the PSP, the nature of the violation and the penalty, as applicable.

How to apply for registration

1. Create an account in PSP Connect

PSPs will not be able to register without an account in PSP Connect.

You will be able to access PSP Connect once registration opens.

2. Prepare your information

Fill in the registration application form in PSP Connect. Information you will need to provide includes (if applicable):

• contact information, including for any third parties, agents and mandataries, and affiliated entities
• business structure, ownership, debtholders and key staff
• retail payment functions that you perform or plan to perform, including any agents and mandataries or affiliates that may be performing retail payment functions on your behalf
• the actual or projected values and volumes of end-user funds held, both inside and outside of Canada
• the actual or projected number of end-users, both inside and outside of Canada
• the method(s) you use or plan to use to safeguard end-user funds
• whether you have in place or have plans to establish a risk management and incident response framework
• any registrations for retail payment activities with FINTRAC or under any other federal, provincial or territorial act

3. Pay the registration application fee

You will be asked to pay a prescribed one-time, non-refundable registration application fee when submitting your application. This fee must be paid in full using a credit card or an electronic funds transfer. We will start assessing your application only once you have paid the application fee.

4. Complete the application form

To help you gather the documents needed to complete the application form, refer to the How to complete a registration application: A step-by-step guide.

What to expect after submitting an application

Applicants will receive a notice through PSP Connect confirming receipt of the application and registration fee. Submitted applications cannot be cancelled.

We will then begin reviewing the application. Applicants may need to respond to requests for information to allow us to process their application.

During the review period, we will share the applications of individuals and entities who meet the registration criteria of the RPAA with:

• the Department of Finance Canada to conduct a national security review
• FINTRAC

Once registered, PSPs must:

• comply with the requirements of the RPAA
• pay an annual assessment fee

Registration decisions

We will publish registration decisions on our website after the transition period, including lists of:

• registered PSPs
• individuals or entities that had their registration refused or PSPs that had their registration revoked and the reasons why, including if a PSP has stopped operating

Refused or revoked registrations

Registration may be refused or revoked if the applicant or PSP:

• fails to meet the criteria for registration
• fails to provide additional information that was requested
• provides false or misleading information
• ceases to perform retail payment activities
• commits a violation under the RPAA
• fails to pay the annual assessment fee

We can also refuse or revoke registration from applicants or PSPs based on information provided by FINTRAC.

We must refuse or revoke registration under a directive from the Minister of Finance if:

• national security reasons exist
• the applicant fails to provide additional information to the Minister
• the applicant fails to comply with undertakings or conditions issued by the Minister
• the applicant provides false or misleading information to the Minister

Reviews and appeals of registration decisions

If a registration is refused or revoked, an individual or entity can request a review within 30 days following the day on which they receive the decision.

The RPAA allows for two kinds of reviews: one by the Governor of the Bank of Canada and one by the Minister of Finance.

Governor’s review

Individuals or entities whose registration has been refused or revoked can request that the Governor of the Bank of Canada review the decision.

The Governor may assign a delegate to issue a ruling on the review, known as a Governor’s decision. Information about the delegation of the Governor’s powers, duties and functions was published in the Canada Gazette on June 15, 2024.

The Governor or delegate will analyze the request and either confirm or overturn the original decision. Individual and entities can appeal a Governor’s decision to the Federal Court.

Minister of Finance review

An individual or entity whose registration has been refused or revoked by a directive from the Minister of Finance can request a review by the Minister.

The Minister or a delegate will analyze the request along with the original decision and either uphold the decision or make a different one.

Individuals or entities can appeal the Minister of Finance’s decision to the Federal Court.

New applications for registration

Registered PSPs must submit a new registration application if:

• an individual or entity plans to acquire control over them
• a state-owned enterprise plans to acquire the right to appoint the PSP’s chief executive officer or other senior management, to acquire rights to elect members of the PSP’s board of directors, or to acquire an ownership interest in them

Disclaimer

We may update this information before or after the RPAA comes into force to respond to:

• feedback from our registration pilot
• changes in the retail payments sector
• lessons learned through implementing the framework