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ARTICLE · 14 NOVEMBER 2025

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Safeguarding End-User Funds Under The Retail Payment Activities Act

McMillan LLP
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As of September 8, 2025, the ongoing compliance obligations outlined in the Retail Payment Activities Act (Canada) (the "RPAA") came into force.

CanadaFinance and Banking
Shahen Mirakian
Shahen Mirakian
Robert C. Piasentin
Robert C. Piasentin
Isabelle Guevara
Isabelle Guevara
Michael Christ
Michael Christ
Brandon Hsu
Brandon Hsu
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As of September 8, 2025, the ongoing compliance obligations outlined in the Retail Payment Activities Act (Canada) (the "RPAA") came into force. Registered payment service providers and parties that have applied for registration as payment service providers whose applications are in process (collectively, "PSPs") must now comply with various regulatory obligations, one of which requires PSPs that hold end user funds to establish a safeguarding framework (the "Safeguarding Framework"). To support compliance, the Bank of Canada (the "BOC") recently updated its Frequently Asked Questions about retail payments supervision ("FAQs"), which address questions asked by PSPs and their service providers regarding the BOC's expectations for the Safeguarding Framework and other regulatory obligations.

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The foregoing provides only an overview and does not constitute legal advice. Readers are cautioned against making any decisions based on this material alone. Rather, specific legal advice should be obtained.

© McMillan LLP 2025

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