PSP registration refused or revoked? How Bank of Canada review and appeal work

If the Bank of Canada refuses your PSP registration, or tells you it intends to revoke it, you have 30 days to ask for a prescribed review. A delegate of the Governor then has 90 days to decide, and you can appeal that decision to the Federal Court within 30 days of being notified. Bank staff walked through the same process at the 2 November 2026 supervision update and added practical points of their own.

What happens if the Bank refuses or plans to revoke your registration?

A refusal arrives as a written notice that gives the reason. Under section 48 of the Retail Payment Activities Act (RPAA), the Bank may refuse an applicant for listed reasons. They include giving false or misleading information, failing to provide information the Bank asked for, and having committed a violation under the Act. Some refusals are mandatory. The Bank must refuse an applicant if the Minister of Finance issues a directive under section 40, for example for reasons related to national security.

Revocation has an extra step. Under section 52, the Bank issues a notice of intent to revoke that sets out the reason. Grounds include false or misleading information, ceasing to perform retail payment activities and committing a violation. The Bank's policy on refusal or revocation of registration under the RPAA lists all the grounds in its annexes.

A refusal has two further effects. If you applied during the transition period, section 108 let you keep operating only until the Bank notified you of its decision. A refusal notice ends that permission on the day you receive it. Get legal advice on your operating position straight away. Section 51 also requires the Bank to tell FINTRAC in writing about any refusal.

Your name does not go on the public list of refusals and revocations at once. Section 27(2) says the Bank cannot add you until the period for requesting a review has expired or the refusal or revocation has been confirmed on review.

What is the review and appeals process following a refusal of a registration application?

You request a prescribed review through your PSP Connect account within 30 days of being notified. The Governor's delegate decides within 90 days, and if you disagree with that decision you can appeal to the Federal Court within 30 days. Those periods come from sections 31 and 34 of the Retail Payment Activities Regulations.

When this question came up in the audience Q&A at the 2 November 2026 session, staff answered it for all four reviewable decision types and stressed the deadline: "you have 30 days after that decision is issued to you."

They also explained why your request should include the original decision. The review office is independent of the team that made the decision, so it will not already have the notice. As staff put it, "We also suggest that you include the original bank decision that you received." The Bank's reviews and appeals policy asks for the same thing, including the external findings report where there is one, and says all forms for a prescribed review should be completed in PSP Connect.

Which Bank of Canada decisions can be reviewed?

Four decisions can be reviewed: a notice of refusal to register, a notice of intent to revoke registration, a notice of violation (including any administrative monetary penalty) and a notice of default under a compliance agreement. Decisions driven by a ministerial directive follow a separate route through the Minister of Finance.

Staff said at the session that a notice of violation can carry a penalty anywhere from $0 up to $10 million per violation. Our guide to the Bank of Canada notice of violation and its 30-day deadline covers that route in detail.

Who decides the review, and what can they do?

The Governor has delegated prescribed reviews to the Executive Director of Payments and Regulatory Oversight. If that person is absent or cannot act, or the position is vacant, an alternate delegate conducts the review. The Bank's policy says the review is made de novo, so the delegate decides the issues afresh.

The possible outcomes depend on the decision under review. For a refusal, section 50(2) says the Governor must either confirm it or direct the Bank to register the applicant. For a notice of intent to revoke, section 53(2) says the Governor must give you an opportunity to make representations and then direct the Bank to withdraw the notice or revoke the registration. If you let the 30 days pass without asking for a review, section 54 allows the Governor to direct the Bank to revoke.

The Bank's policy, and staff at the session, described the result in general terms: the decision may confirm the original decision, direct staff to take a certain action, or make an independent finding. The policy page also links forms to request an extension, make additional submissions or ask for special accommodations.

Who should you contact once a decision is issued?

Contact the review office. Staff said at the session that some PSPs go back to the team that issued the decision, but once a decision is out, the matter belongs to the review function. Their advice was that PSPs "should reach out to that team because they are independent." The Bank keeps the two functions separate so the review can be decided independently.

What does the Bank publish after a registration decision?

For refusals and revocations, the Bank publishes the grounds in its public list. Section 27(1) of the RPAA requires the Bank to maintain and publish a list of refused applicants and revoked providers that sets out the reasons. The Bank's policy says it will reflect the grounds of a registration review decision in that list of refused or revoked registrations and will not publish the whole decision. For notices of violation and notices of default, it publishes the entire prescribed review decision. Its approach is set out in its policy on issuing public notice of decisions.

Besides the list of refusals and revocations, the Bank keeps the registry of registered payment service providers that section 26 requires and a list of applicants whose reviews are not finalized. Staff said at the session that one prescribed review decision had been published on the Bank's website so far, and suggested PSPs read it.

When can you appeal to the Federal Court?

You can appeal a registration review decision to the Federal Court within 30 days after the day you are notified of it, or within any longer period the court allows (RPAA s. 58(1) and Regulations s. 34). Under section 58(2), the court may dismiss the appeal, set aside the decision and order the Bank to register you or reinstate your registration, or send the matter back to the Governor to decide again.

The appeal sits outside the Bank's process. Staff noted at the session that the route is set out in law and runs through the review first, so a PSP does not go straight to court. For notices of violation, section 84 sets the appeal period at 30 days after the day the decision is served.

How long does the Bank take to decide on an application?

There is no single answer, because the Bank is only one party in the process. For applications submitted after 8 September 2025, the Bank's policy says it has 45 days from the date it considers an application complete to decide whether to refuse it (Regulations s. 30). A national security review can add time.

Under section 34 of the RPAA, the Minister may decide to review an application for national security reasons. The Regulations give the Minister 60 days from receiving the application to decide, extendable by 60 days, and 180 days to complete a review once it starts, with further extensions possible (ss. 26 and 27). Section 35 bars the Bank from registering an applicant during that window unless the Minister says no review will take place.

At the session, staff explained that once the Bank finishes its own review, it passes the file to the Department of Finance, which coordinates the national security review. Because the file moves through several hands, staff said it is hard to say exactly when an application will be completed. Their practical advice was to submit a complete application, since gaps lead to back-and-forth. Our Bank of Canada PSP application documents checklist covers what reviewers usually ask about, and the RPAA registration guide sets out the full process.

Does registration mean the Bank has found you compliant?

No. Registration under the RPAA does not give a PSP a licence, as the Bank's FAQ on retail payments supervision confirms. At the session, staff called the RPAA an activities-based registration regime and said registration does not mean an applicant demonstrated compliance before being registered. Compliance is assessed through supervision after registration, and a registered PSP that later commits a violation can receive a notice of intent to revoke under section 52. Our comparison of MSB and PSP registration in Canada explains how this differs from FINTRAC registration.

What should you do after receiving a refusal or notice of intent?

If you need help preparing a review request or a new application, see our PSP registration services in Canada.

Frequently asked questions

When can we expect all applicants to be reviewed?

The Bank did not give a date. At the 2 November 2026 session, staff said the Bank completes its review and then passes the file to the Department of Finance for the national security review, so timing depends on more than one party. They said the Bank updates the applicants list and the registry very frequently.

What are the biggest lessons that the Bank has learned so far?

One lesson staff named at the session was the need to be clear about what registration means. They said the RPAA is not a licensing regime and that registration does not show a PSP demonstrated compliance beforehand. They also said compliance issues were expected with a new regime.

Can I keep operating while my refusal is under review?

If you were operating under the transitional exemption in section 108 of the RPAA, it ends on the day the Bank notifies you of a refusal. Applicants who filed after 8 September 2025 must be registered before they perform any retail payment activities. Take legal advice on your own position.

Will a refusal be made public?

Yes, once the review period has expired or the refusal is confirmed. The Bank adds you to its list of refused or revoked registrations with the reasons, and does not publish the full review decision for registration matters.

What if I miss the 30-day deadline?

For a notice of intent to revoke, section 54 lets the Governor direct the Bank to revoke your registration if no review is requested in time. For a refusal, the Bank can add you to the public list once the review period has expired. The Bank's policy links a form to request an extension, so act before the period ends.