Regulators · Resource briefing
Bank of Canada — Retail Payments Supervision
Assess payment-service-provider scope under the RPAA and the separate duties around operational risk and end-user funds.
Independent editorial summary of Bank of Canada material. Not legal advice or a statement from the authority.
Payment functions drive the scope assessment
The Retail Payment Activities Act creates a supervisory framework for payment service providers. Assess your electronic payment activities, Canadian connection and applicable exclusions using the Bank of Canada’s guidance. FINTRAC registration alone does not answer whether the RPAA applies.
Map the payment flow from customer instruction to settlement: who maintains accounts, holds funds, initiates a payment, transmits instructions or performs clearing and settlement functions? The actual role matters more than whether the product is marketed as a wallet or an MSB service.
Registration and supervision are separate from AML duties
The Bank’s framework focuses on operational risk and safeguarding end-user funds. It does not replace FINTRAC obligations. A business may need to satisfy both frameworks, with different records, reporting responsibilities and controls.
Translate the framework into operating controls
Use the official supervision hub for scope guidance, registration information and current supervisory requirements. Where relevant, connect your operational-risk framework to service providers, incident handling and business continuity, and identify how end-user funds are held and safeguarded.
Operational checklist
- Draw the payment flow and assign each function to a legal entity.
- Check Canadian scope and exclusions in current Bank guidance.
- Identify whether the business holds end-user funds.
- Assign owners for operational risk, incidents, safeguarding and regulatory submissions.
Source & current guidance
Confirm the requirements for your activities in the original material. Official guidance and participation terms can change.
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