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ARTICLE · 12 DECEMBER 2024

Retail Payment Activities Act—A Deeper Dive Into When Registration Is Required

Bennett Jones LLP
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This post is a follow-up to our earlier blog, Upcoming Retail Payment Activities Act Regulation—Updates from the Bank of Canada, where we summarized...

CanadaFinance and Banking

This post is a follow-up to our earlier blog, Upcoming Retail Payment Activities Act Regulation—Updates from the Bank of Canada, where we summarized the four-step test under the Retail Payment Activities Act (RPAA) to determine whether your business qualifies as a payment service provider (PSP) requiring registration with the Bank of Canada (the Bank).

Businesses determined to be a PSP under the RPAA's four-step test were required to register with the Bank via the PSP Connect portal during the registration window from November 1 to November 15, 2024 (the Registration Window) to carry on business as a PSP immediately following the Registration Window. While businesses can still register after this Registration Window, this would technically result in a 60-day period during which the business would not be permitted to operate as a PSP, as businesses are required to submit their registration applications at least 60 days prior to commencing their retail payment

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