On April 30, 2021, as part of the 2021 federal budget, the
Canadian government introduced Bill C-30, An Act to implement
certain provisions of the budget tabled in Parliament on April 19,
2021, and other measures (the "Bill")
1 for first reading in Parliament. Included in the
Bill is the initial draft of the proposed Retail Payment
Activities Act (the "RPAA"), which, if enacted,
would represent the first regulatory oversight framework for retail
payment services providers in the Canadian market.
Application of the RPAA
The RPAA, as drafted, would apply to "payment service
providers" (PSPs) located both in and outside Canada.
Both a PSP situated within Canada that performs a "retail
payment activity" for an end-user in Canada and a PSP situated
outside Canada that "directs" retail payment activities
at persons in Canada would have the same responsibilities under the
RPAA. The definition of a "retail payment activity"
leaves open the possibility that the RPAA will