RPAA assessment fees in 2027: what PSPs should expect from Bank of Canada cost recovery

Registered payment service providers (PSPs) should plan for RPAA assessment fees, the annual charge the Bank of Canada will use to recover its supervision costs, from 2027. The fee regulations are not final and the billing formula has not been published. At the Bank's 2 November 2026 supervision update, staff said they "expect cost recovery to come into force in 2027" and that "these timelines and coming into force dates may be subject to change."

Are RPAA assessment fees in force yet?

No. As of 3 November 2026, no PSP has been charged an annual assessment fee under the Retail Payment Activities Act (RPAA). The only fee PSPs pay today is the registration application fee, which the Bank's retail payments supervision FAQ puts at $2,500 and describes as non-refundable.

The legal picture has two layers:

Staff at the session said the assessment fee regulations are still subject to finalization by the Department of Finance and Treasury Board. They added that detailed guidance will be published on the Bank's website once the regulations are final, and that they expect it before the regulations come into force.

Has a fee regulation been pre-published in the Canada Gazette?

Not in 2026. We checked every 2026 issue of the Canada Gazette, Part I, up to 31 October 2026 and found no proposed assessment fee regulations for PSPs. The October 2026 proposed Stablecoin Regulations include a fee formula, but it applies to stablecoin issuers. Nothing from Finance Canada or the Bank sets out a final PSP formula.

The one published PSP formula dates from the draft Retail Payment Activities Regulations, pre-published in the Canada Gazette, Part I, on 11 February 2023. The final regulations (SOR/2023-229) left the formula out. The Regulatory Impact Analysis Statement explains that the formula "will be finalized after PSPs begin registering", because registration data was needed to understand the number of PSPs and their characteristics. Finance Canada's forward regulatory plan entry says the same.

At the 2 November session, staff said the final framework will follow the approach of the pre-published regulations and take account of consultation feedback. The 2023 draft would have split the Bank's net costs this way:

Treat this table as background. It was withdrawn from the final regulations, and the final weights may be different. Staff said plainly that they could not yet state the exact metrics that will be used for billing. They did confirm the direction: fees will reflect each PSP's payment activity, larger PSPs will pay a larger share, and the design aims to keep barriers low for smaller PSPs and new entrants. Staff also said the Bank expects most PSPs to be able to "predict their annual assessment fees upfront".

When will PSPs receive their first assessment fee invoice?

Staff said initial billings are expected in spring 2027, assuming the regulations come into force for 2027. They described this sequence:

Interim amounts are credited against the final bill. In the speaker's words, "It's not an additional charge." The legislation allows for this structure: section 99(4) of the RPAA and the new section 30.2(5) of the Bank of Canada Act (neither yet in force) both let the Bank prepare an interim assessment during each calendar year.

The annual report, due 31 March each year, will drive the fee. Staff said PSP Connect is being updated to include a clear section on billing metrics.

Does the Bank invoice before September 30 or in the spring?

Both statements can be true, because the September date comes from the statute. One remark at the session said the Bank will "invoice PSPs before September 30th each year", while the rest of the presentation described spring billing.

The published legislation, although not yet in force, sets out what happens before September 30. Section 99(1) of the RPAA, and the new section 30.2(1) of the Bank of Canada Act that replaces it, both say the Bank must, before September 30 each year, ascertain its expenses for the preceding calendar year. The Bank then assesses each PSP's share "as soon as feasible" after that. So September 30 is the statutory deadline for working out the prior year's costs, and a spring invoice falls before it. Until the regulations and the Bank's guidance are published, plan for the spring timing staff described and treat September 30 as the outer limit for the prior-year calculation.

How will assessment fee invoices and payments work?

Staff gave the following operational details. They are session remarks, not published guidance:

The consequences of non-payment are already written into the legislation, although the fee provisions are not yet in force:

How are RPAA assessment fees different from FINTRAC charges?

They are separate charges under separate statutes. Many PSPs are also money services businesses, so they may already receive a FINTRAC assessment of expenses invoice under anti-money laundering law. That charge has its own thresholds and method, explained in our article on how FINTRAC assessment of expenses charges are calculated. Paying one does not reduce or replace the other. Budget for both if both regimes apply to you. Our MSB and PSP comparison explains when a business falls under each regime.

How should PSPs prepare for RPAA assessment fees now?

The fee amount is unknown, but the inputs and the process are clear enough to act on.

If you are still building the controls the annual report describes, our RPAA operational risk framework guide covers them. Businesses not yet registered can start with the RPAA registration guide. Registration metrics are expected to set the interim bill for PSPs that register after the 2026 reporting period. If you want help preparing metrics or a registration file, see our PSP registration service in Canada.

Frequently asked questions

What will be the significant changes in oversight and regulation over the next 12 months?

For the RPAA, staff at the 2 November 2026 session said they do not anticipate major shifts and expect continued supervision through reporting, information requests, assessments and enforcement where needed. The one specific development they named was the assessment fee formula covered in the cost recovery presentation.

Will the interim bill be charged on top of the final bill?

No. Staff said all interim billings will be deducted from final billings. The interim bill is a payment on account toward the year's final assessment.

How much will RPAA assessment fees cost?

Nobody can say yet. The regulations and billing metrics have not been published. Staff said fees will reflect payment activity, with larger PSPs paying a larger share, and that the Bank expects most PSPs to be able to predict their fees upfront once the formula is set.

Can a PSP lose its registration for not paying assessment fees?

Yes, potentially. The Retail Payment Activities Regulations list failure to pay an assessment or interim assessment as a prescribed reason for a notice of intent to revoke registration. Unpaid amounts are also a debt due to the Bank and may attract interest.

Is RPAA registration a licence, and does paying fees mean the Bank has approved my compliance?

No to both. Registration under the RPAA is not a licence. Staff described it as an activities-based registration regime and said registration does not mean a PSP demonstrated compliance before it was registered. Assessment fees pay for supervision and say nothing about a PSP's compliance.