PSP registration Canada
Payment service providers operating in Canada are now subject to two separate federal registrations that come from different regulators: FINTRAC registration as a Money Service Business under the PCMLTFA, and Bank of Canada registration under the Retail Payment Activities Act (RPAA). The RPAA risk management and funds safeguarding requirements have applied since September 8, 2025. Penalties for non-compliance can reach $10,000,000 CAD per very serious violation under the RPAA, and up to $20,000,000 for an entity ($4,000,000 for an individual) under the PCMLTFA since Bill C-12.
ComplyFactor manages dual PSP registration across Canada: FINTRAC MSB registration and Bank of Canada RPAA registration handled together, with the AML compliance program and operational risk framework required to support both.
PSP registration in Canada: two regulators, two registrations
Before the RPAA, a Canadian payment service provider registered with FINTRAC as an MSB and its federal registration obligations were largely complete. PSPs now answer to two federal regulators with different mandates, portals, obligations, and enforcement powers.
Related reading: the RPAA registration process with the Bank of Canada
FINTRAC: MSB registration
Bank of Canada: RPAA registration
Do you need to register as a PSP under the RPAA?
The RPAA applies to any individual or entity that performs one or more retail payment functions in Canada, or directs those functions at Canadian end-users, regardless of where the business is incorporated. The Act is activity-based: what matters is what your business does.
Providing or maintaining a payment account
Providing an account that stores monetary value or payment credentials for end-users (a digital wallet, stored-balance account, or platform payment account) is a common trigger for Canadian fintechs.
Holding end-user funds
Holding funds on behalf of end-users, as a float, in escrow, or in a pooled account, is a retail payment function. It triggers registration and end-user fund safeguarding obligations.
Initiating electronic fund
transfers
Initiating an EFT on behalf of a client (wire, ACH, Interac e-Transfer, or cross-border payment) is a core retail payment activity. It is the broadest trigger, capturing most payment platforms and remittance operators.
Authorizing or clearing transactions
Sitting in the transaction chain as an authorizer or clearer (for example, orchestration platforms, gateways, and intermediaries that transmit payment instructions) may trigger the RPAA even without holding funds. The Act covers the payment instruction chain as well as the movement of funds.
International PSPs serving Canadian end-users
The RPAA applies extraterritorially. A business incorporated outside Canada that performs retail payment activities directed at Canadian end-users (for example, through Canadian-facing marketing, CAD pricing, or a .ca domain) must register with the Bank of Canada before commencing.
Based outside Canada? Read our guide to Canadian MSB and PSP registration for foreign companies
Registered but struggling to open accounts? See how to get banking for your Canadian MSB or PSP
Common misconception: "Our bank partner is regulated, so we're excluded too." No, bank and authorized foreign bank exclusions do not extend automatically to partner businesses. Each entity in the payment chain must assess its own activities independently.
FINTRAC registration vs Bank of Canada RPAA: what each covers
The two registrations are independent and both mandatory. Here is how they differ.
Only need FINTRAC and not the RPAA? If your business does not perform retail payment activities, see our MSB Registration Canada page instead.
How to register as a PSP in Canada: FINTRAC + RPAA
Dual registration is two separate processes, two portals, and two timelines. They can, and should, be run concurrently.
Confirm your MSB activity category
Determine which PCMLTFA category applies. Funds transfer is most common for PSPs, and many also qualify as foreign exchange or virtual currency dealers depending on product mix.
Build your AML compliance program
Written policies, risk assessment, and training framework must be in place before your FINTRAC registration is active. They may be examined whenever FINTRAC reviews your business.
Submit FINTRAC online application
Complete the FINTRAC registration form (MSB activities, compliance officer designation, and locations), submitted on your behalf with all activity declarations. No application fee.
RPAA self-assessment
Use the Bank of Canada's self-assessment tool to confirm the RPAA applies to your activities. The result is the basis of your application, so an incorrect conclusion carries through every later step.
Create PSP Connect account & apply
PSP Connect is the Bank of Canada's portal. The application requires entity details, directors and beneficial owners, payment activities and EFT flows, fund-safeguarding arrangements, operational risk and incident-response frameworks, and third-party disclosures.
Pay the fee & submit
The Bank of Canada charges a non-refundable $2,500 CAD registration fee per application. Processing time depends on the Bank of Canada's review, and applicants typically have 15 days to respond to its requests for information.
Register before you start
New entrants should apply to the Bank of Canada as soon as possible. The Bank starts assessing an application only once the application fee has been paid.
RPAA compliance obligations: what PSPs must do after registration
RPAA registration is the entry point to an ongoing supervisory relationship with the Bank of Canada. These obligations begin on the date of registration and continue while the business is registered.
FINTRAC obligations continue. RPAA registration does not replace or reduce your FINTRAC obligations. Both run concurrently. Your AML compliance program, STR/EFTR filing, biennial effectiveness review, and compliance officer designation remain active under the PCMLTFA alongside every RPAA obligation.
What our PSP registration service covers
We manage both registrations together, FINTRAC and RPAA, so your business does not have to handle two regulatory portals and two sets of documentation alone.
RPAA activity assessment
We assess your specific payment functions against the RPAA's statutory criteria, confirming which activities trigger registration and whether any exclusions apply to your model.
FINTRAC MSB registration
FINTRAC registration covering activity category confirmation, compliance officer designation, application submission, and the AML compliance program build.
Bank of Canada RPAA application
Full RPAA application via PSP Connect: entity and ownership documentation, payment activity description, EFT flow mapping, and all required disclosures.
AML compliance program (PCMLTFA)
Written policies, risk assessment, and training framework to support your FINTRAC registration, written for your payment activities and customer types.
RPAA operational risk framework
Documented framework covering technology risk, cyber risk, third-party dependencies, business continuity, and incident response. It is required for RPAA registration and ongoing oversight.
End-user fund safeguarding documentation
If you hold end-user funds, we document your safeguarding arrangement in the Bank of Canada's required format, including the designated account structure and reconciliation procedures.
Post-registration compliance setup
Annual report calendar, material-change notification procedures, FINTRAC reporting obligations, and biennial audit scheduling, all established before your registrations are active.
PSP registration timelines & costs
Dual registration has a different timeline and cost structure for each regulator. The RPAA path is the critical path for new PSPs, and FINTRAC runs concurrently.
New entrants: If you have not yet started retail payment activities, apply to the Bank of Canada as early as you can. The Bank's review is the critical path for new PSPs, so budget accordingly.
What Canadian PSPs receive
A dual-registration engagement covers both applications plus the compliance documentation that supports them.
Why Canadian PSPs choose ComplyFactor
Both registrations prepared concurrently, with the AML program and the operational risk framework built together.
Both registrations managed together
We manage both registrations together and build both frameworks concurrently, so the FINTRAC and Bank of Canada work runs as one project.
RPAA operational risk framework included
RPAA registration requires an operational risk framework alongside the AML program. We cover both the AML program and the operational risk documentation the Bank of Canada reviews.
New-entrant timing
We plan your timeline around the Bank of Canada's review so that payment activities do not start before your registration is in place.
International PSPs: Canada market entry
We support international payment businesses registering with both regulators for the first time. That covers the extraterritorial RPAA application, Canadian fund safeguarding, and the FINTRAC AML program.
Fixed-scope pricing for both registrations
One engagement letter and one fixed price cover both registrations. FINTRAC and RPAA work are not billed separately.
Frequently asked questions: PSP registration Canada
Most payment service providers operating in Canada need both registrations. FINTRAC registration as a Money Service Business is required if your business performs MSB activities under the PCMLTFA, including funds transfer and virtual currency dealing. Bank of Canada registration under the RPAA is required if your business performs retail payment functions: maintaining payment accounts, holding end-user funds, initiating EFTs, or authorizing transactions. The two obligations are independent of each other. The RPAA risk management and funds safeguarding requirements have applied since September 8, 2025, and registration opened on November 1, 2024.
The Retail Payment Activities Act (RPAA) is federal legislation administered by the Bank of Canada that established a supervisory framework for payment service providers. It came into force in two phases: the registration window opened November 1, 2024 for PSPs already operating, and supervision of the risk management and funds safeguarding requirements began September 8, 2025. PSPs that applied during the November 2024 window could continue operating through the transition period. New entrants since September 8, 2025 must register and receive Bank of Canada approval before commencing retail payment activities.
FINTRAC MSB registration carries no government fee. Bank of Canada RPAA registration carries a $2,500 CAD application fee, which is non-refundable. ComplyFactor's service fee for dual registration management, including the AML compliance program, operational risk framework, and both applications, is agreed in a written proposal before any work begins. Contact us at +1 807 806 0444 for a quote specific to your business.
Yes, if you perform retail payment activities directed at end-users in Canada. The RPAA applies extraterritorially: the test is whether your business performs retail payment functions for Canadian end-users, wherever it is incorporated. Canadian-facing marketing, CAD-denominated pricing, or a .ca domain are indicators the Bank of Canada uses to assess whether a foreign business is directing services at Canadian users. FINTRAC registration requirements similarly apply to foreign businesses with Canadian customers or operations.
A business that has not yet performed retail payment activities should apply to the Bank of Canada as soon as possible and be registered before it begins those activities. The Bank starts assessing an application only once the application fee has been paid, and it does not state a fixed processing time. ComplyFactor plans registration timelines around the Bank's review so that new PSPs are registered before payment activities begin.
If your business holds funds on behalf of end-users (in a digital wallet, a stored-balance account, or any payment account), those funds must be safeguarded under the RPAA. Safeguarding means holding the funds in a designated account at a Canadian financial institution, separate from the business's operating funds, with documentation of the arrangement filed with the Bank of Canada. The safeguarding obligation applies from the date of RPAA registration.
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