Canada RPAA PSP Registration: An Operator Reference
Who must register with the Bank of Canada under the Retail Payment Activities Act, what the application requires, and the obligations that follow registration.
Bank of Canada registration under the Retail Payment Activities Act is mandatory for any PSP active in Canada — including a foreign PSP with no Canadian office, if it directs activities at Canadians. Who's caught, what registration requires, and what follows.
A PSP must register with the Bank of Canada under the RPAA if it meets all four Bank criteria: a PSP performing non-incidental payment functions; a retail payment activity involving an EFT; the geographic scope test; and no applicable exclusion. The geographic test catches foreign PSPs with no Canadian office: it applies if the PSP directs retail payment activities at people in Canada — the Bank states foreign PSPs must register even without Canadian incorporation or FINTRAC registration. Registration carries a one-time, CPI-indexed fee ($2,500 for the year the fee section took effect) and a Canadian agent-for-service requirement for offshore applicants. Registered PSPs run a risk-management framework, safeguard held funds, and file annual and change reports — in force since 8 September 2025. Non-compliance can draw penalties to $10,000,000 per violation, published by name.
An operator asking whether they need to register under Canada's Retail Payment Activities Act (RPAA) is usually asking two questions at once: does the statute reach them at all, and if it does, what will the Bank of Canada actually require. The first has a specific, testable answer written into the Act. The second has three layers — the Act itself, the Retail Payment Activities Regulations (RPAR) that fill in its prescribed details, and Bank of Canada supervisory guidance that explains how the Bank applies both — and conflating them is the easiest way to get the analysis wrong. This piece keeps the three separate throughout.
Scope note. The Canada market page covers Canada's payment rails, card networks, and PSP landscape broadly; this article is the RPAA registration layer specifically. For the same "who is actually caught" analysis applied to a different regime, see US money transmitter licensing and payment models. This is not legal advice; scope and exclusion questions turn on specific facts worth confirming with counsel.
Who has to register: the Bank of Canada's four criteria
The Bank of Canada frames registration as a four-part test: an individual or entity must meet all four to be required to register. First, be a payment service provider — one performing payment functions "as a service or business activity that is not incidental to another service or business activity." That clause is not a separate exclusion bolted onto the Act — it's baked into the definition itself. A business whose core activity is something else — selling goods, running a marketplace, providing software — and whose payment handling is incidental to that core activity does not become a PSP by virtue of touching money.
Second, perform a retail payment activity — a payment function performed in relation to an electronic funds transfer made in Canadian or foreign currency. Digital currencies currently fall outside this, per the Bank's own framing; nothing in the Regulations this session retrieved prescribes the "unit" criteria needed to bring one into scope. Third, meet the geographic scope test — the one most likely to surprise a foreign operator, covered below. Fourth, perform payment functions that aren't excluded — also covered below.
The five payment functions the Act regulates: maintaining an account for an end user in relation to an EFT; holding an end user's funds until withdrawn or transferred; initiating an EFT at an end user's request; authorizing, transmitting, or facilitating an EFT instruction; and providing clearing or settlement services. Any one, performed as a non-incidental business activity, is enough — holding customer funds is not the only trigger.
The foreign-PSP scope test — and why an office in Canada isn't the deciding fact
The Act applies domestically to any PSP with a place of business in Canada, regardless of where its end users are. The part that catches foreign operators off guard is section 5: the Act also applies to a PSP with no place of business in Canada if it performs a retail payment activity for an end user in Canada and "directs retail payment activities at individuals or entities that are in Canada."
The Bank of Canada is direct about what that means: "Foreign PSPs who are subject to the RPAA are required to register with us even if they are not incorporated in Canada" — or registered as a foreign money-services business with FINTRAC. And there's no lighter track once caught: "They will be supervised and generally treated in the same manner as a domestic PSP and will be subject to our enforcement actions." A foreign PSP that meets the test files the same application and carries the same AML-adjacent enforcement exposure as a Canadian one.
Neither the Act nor the Bank's published guidance defines exactly where "directing activity at" Canada begins — there's no bright-line list of what counts (CAD pricing, Canadian marketing spend, a Canadian-facing app listing) the way some other jurisdictions spell one out. An operator with meaningful, deliberate Canadian volume should assume the test is met; one whose Canadian users arrive only through general global availability sits in genuinely uncertain territory worth a specific legal read rather than a guess.
Exclusions operators actually run into
Beyond the incidental-activity filter built into the PSP definition, the Act excludes: instruments usable only with a single merchant or a defined merchant group (closed-loop gift cards and similar); transactions giving effect to an eligible financial contract or a prescribed securities transaction; ATM cash withdrawals; anything performed through a system designated under the Payment Clearing and Settlement Act; and internal transfers between affiliated entities where the PSP performing the function is one of the affiliates and no other PSP is involved.
On entities, the Act names banks and authorized foreign banks (for their Canadian business), provincially regulated credit unions and caisses populaires, provincial Crown deposit-takers, insurance companies, trust and loan companies, Payments Canada, and the Bank of Canada itself. The Bank's own supervisory-framework page adds SWIFT to its excluded-entities list — a characterization on the Bank's guidance page, not verbatim in the Act's own s.9 list, so treat it as applied position rather than a directly citable statutory exclusion. An agent or mandatary of an already-registered PSP is also excluded, provided it's on that PSP's filed agent list and acting within its authority.
What the application actually requires
Registration runs through the Bank's PSP Connect portal. The application covers the applicant's structure, ownership and key staff; its agents, mandataries and affiliated entities; volume and value figures — actual or projected — for the retail payment activities performed or planned; the number of end users; how end-user funds are or will be safeguarded; and whether a risk-management and incident-response framework is in place or planned, plus declarations on FINTRAC registration, Canadian place of business, and any overlapping provincial registration. The one requirement specific to foreign applicants: one with no Canadian place of business must name a Canadian agent or mandatary authorized to accept notices and orders served under the Act on its behalf — the Bank's practical substitute for a local presence it can serve process on.
The fee is a one-time, non-refundable charge, paid before the Bank starts assessing the application. The Regulations set it at $2,500 for the calendar year the fee provision came into force, indexed in later years to the ratio of the September Consumer Price Index between the prior year and the year the provision took effect, with a floor against ever falling below the prior year's fee. This article doesn't state a current-year dollar figure, since that requires a CPI calculation this session didn't run; confirm the exact current amount through PSP Connect at filing.
Once a complete application is on file, the Bank shares it with the Department of Finance for a national security screening and with FINTRAC. Most applications clear without a formal review being opened. If the Minister does open one, the Regulations set the clock: 60 days to decide whether to review at all (extendable by another 60), then 180 days to conduct a review once opened (extendable in further 180-day blocks). Outside that track, neither source retrieved for this article states a fixed turnaround for an ordinary registration decision — so a general elapsed-months figure isn't something this article can support, and none is stated here.
Registration can be refused or revoked on several grounds — false or misleading information, being found guilty of certain offences under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, FINTRAC penalty or decision notices issued in the five years before the application, failing to respond to an information request, or committing a violation under the Act itself. One backstop is specific to PSPs with no Canadian place of business: the Bank must refuse or revoke such a PSP's registration if it has an unpaid administrative monetary penalty (AMP) still outstanding 30 days after all proceedings on it have ended — a mechanism covered further below. The Bank maintains and publishes both a registry of registered PSPs and a list of refusals and revocations, with reasons.
The obligations that follow registration
Three recurring duties, all in force since 8 September 2025 — a date confirmed independently in the Act's own coming-into-force note and two separate Bank of Canada pages.
Risk management and incident response. A registered PSP must establish, implement and maintain a framework for identifying and mitigating operational risk and responding to incidents, and must report to the Bank, without delay, any incident materially impacting an end user, another PSP, or certain clearing-and-settlement participants.
Safeguarding of funds. For any end-user funds a PSP holds until withdrawal or transfer, the Act sets out three options: a dedicated trust account; an account and manner set by regulation; or a segregated account backed by insurance or a guarantee at least equal to the amount held. Only two are currently usable — this session searched the full retrieved Regulations text for a prescribed account or manner under the Act's middle option and found none, so a PSP choosing that route today has no regulation to follow. For the insured-account route, the Regulations require the account provider and insurer to be a bank, credit union, insurer, trust or loan company or comparable entity (or a comparably regulated foreign financial institution) unaffiliated with the PSP, require the proceeds stay outside the PSP's estate on insolvency, and require the Bank get at least 30 days' notice before any cancellation.
Reporting. An annual report to the Bank covering the risk-management framework and, where applicable, the safeguarding arrangement in place, plus notice before any significant change to how a retail payment activity is performed or before starting a new one — "significant" meaning a change that could reasonably be expected to materially affect operational risk or how end-user funds are safeguarded.
Enforcement: what actually happens on non-compliance
The Bank's toolkit runs from a warning letter through a compliance agreement to a formal notice of violation carrying an administrative monetary penalty (AMP) — capped by regulation at $10,000,000 per violation. The Regulations make that cap explicit by tier: each violation is classified as serious or very serious against the Regulations' own schedule, with penalties running up to $1,000,000 for a serious violation and up to $10,000,000 for a very serious one (SOR/2023-229, ss.47-48) — the same $10,000,000 figure is also the outer ceiling the Act allows regulations to set (RPAA s.101(1)(k)). A notice of violation can come bundled with an offer: enter a compliance agreement to fix the issue on a defined timeline, and the penalty is cut in half. Miss that agreement, and the PSP owes the unpaid half plus an additional penalty the Regulations set equal to the original amount (SOR/2023-229, s.50) — a missed deadline that doubles exposure rather than resetting it. Separately, the Bank can issue a compliance order directing a PSP to stop, refrain, or take remedial steps — including on a temporary basis without prior representations where delay itself would be harmful — and can apply to a superior court to enforce compliance directly.
A structural point worth precision. The Act states: "For greater certainty, a violation is not an offence and, accordingly, section 126 of the Criminal Code does not apply in respect of a violation." Due diligence is an available defence. This is a civil, administrative regime, not a criminal one — but it's not toothless. The Bank publishes enforcement outcomes once proceedings conclude, naming the PSP, describing the violation, and stating the penalty. The limitation period favours the regulator: "No notice of violation is to be issued after the second anniversary of the day on which the Bank becomes aware of the acts or omissions that constitute the alleged violation." The clock runs from discovery, not conduct.
The registration timeline, and the gap that's worth checking directly
Parliament assented to the RPAA on 29 June 2021, but the Act came into force in stages. The Regulations (SOR/2023-229) were registered on 3 November 2023 (P.C. 2023-1106), per the regulation's own header. The registration machinery — the ability to submit an application — began on 1 November 2024, with s.23 (registration actually being required) following on 16 November 2024. PSPs already active as of that first date had a short transitional filing window to get an application in without being in violation from day one; that window closed in November 2024 and has no bearing on a PSP registering today, which is simply required to register before performing any retail payment activity, full stop. The bulk of the operational substance — the Bank's duty to register applicants, the risk-management and safeguarding requirements, the annual report, and the public registry and refusal/revocation list — came into force on 8 September 2025.
One gap is worth flagging rather than smoothing over. The Act's own Part 6, covering an annual assessment fee that would fund the Bank's supervisory costs, is marked "not in force" against each of its two sections in the Department of Justice's consolidated text, current to 21 June 2026. Separately, the Bank of Canada's retail-payments overview page lists an annual assessment fee, alongside the registration fee, among the tools it uses to recover its costs. This article cannot resolve that gap — no announcement of Part 6 coming into force turned up — so treat it as a status to confirm directly with the Bank. The one-time registration fee, by contrast, is unambiguously in force and payable at filing.
Keeping the three layers straight
The Act sets the registration duty, the geographic test, the named exclusions, and the outer limits of what can be regulated — including the $10,000,000 AMP ceiling. The Regulations fill in nearly every number an operator needs to plan around: the fee formula, the national-security-review clock, the prescribed periods for refusal and review, and the operative detail behind the Act's safeguarding options. Bank of Canada guidance restates and applies both, and is where the Bank's own working interpretation of open questions — like where the directing-activity-at-Canada line actually falls — lives in practice. Treating any one of the three as if it were the other is where an otherwise correct registration analysis goes wrong.
Sources & methodology (21)
'payment service provider means an individual or entity that performs payment functions as a service or business activity that is not incidental to another service or business activity'
Retrieved HTML (166,365 bytes), current to 2026-06-21 per the Act's own header, stripped to plain text and read directly in this session. IMPORTANT: the citation ID for this Act is R-7.36 — R-4.6 resolves to an unrelated statute (the Reduction of Recidivism Framework Act) and must never be used for the RPAA.
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'Subject to sections 6 to 10, this Act also applies in respect of any retail payment activity that is performed for an end user in Canada by a payment service provider that does not have a place of business in Canada but directs retail payment activities at individuals or entities that are in Canada.'
The geographic scope test that catches foreign PSPs with no Canadian office
Same retrieved Act text. Contrast with s.4, which applies the Act to any PSP with a place of business in Canada regardless of where its end users are.
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Exclusions: s.6 excludes closed-loop merchant/merchant-group instruments, transactions giving effect to an eligible financial contract or a prescribed securities transaction, ATM cash withdrawals, and prescribed activities; s.7 excludes payment functions performed using a system designated under the Payment Clearing and Settlement Act; s.8 excludes internal transactions between affiliated entities where the PSP is one of the affiliates and no other PSP is involved; s.9 excludes named entities — banks, authorized foreign banks (in respect of Canadian business), provincially regulated credit unions/savings and credit unions/caisses populaires and their central associations, provincial Crown deposit-takers, insurance companies, trust and loan companies, the Canadian Payments Association (Payments Canada), the Bank of Canada itself, and prescribed entities; s.10 excludes an agent or mandatary of a registered PSP acting within its authority and on the PSP's filed agent list.
Same retrieved Act text, ss.6-10 read in full.
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'Individuals or entities who meet all four of the following criteria must register with us by submitting an application and paying a registration fee': (1) be a PSP performing payment functions not incidental to another activity; (2) perform a retail payment activity involving an EFT made in Canadian or foreign currencies, excluding digital currencies; (3) meet the geographic scope test (place of business in Canada regardless of end-user location, or place of business outside Canada while performing activity for an end user in Canada and directing activity at people in Canada); (4) perform payment functions not excluded under the RPAA and its regulations.
The Bank of Canada's own four-criteria framing of who must register
Retrieved HTML (194,247 bytes), stripped to plain text and read directly in this session. This is Bank of Canada guidance restating and organizing the statutory test — treated as guidance layered on the Act, not the Act itself.
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'Foreign PSPs who are subject to the RPAA are required to register with us even if they are not incorporated in Canada' [or registered as a foreign money service business with FINTRAC]. 'They will be supervised and generally treated in the same manner as a domestic PSP and will be subject to our enforcement actions.'
Same retrieved page. Also on this page: excluded entities/activities list, including SWIFT among excluded entities — a Bank of Canada characterization not found verbatim in RPAA s.9's own list.
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'Foreign PSPs must identify in their registration application any agents or mandataries acting on their behalf in Canada. We will provide those agents or mandataries with notices given or served as well as orders made under the RPAA.'
The Canadian agent-for-service requirement for foreign applicants
Same retrieved page; corresponds to RPAA s.29(1)(o), which requires an applicant with no Canadian place of business to name a Canada-based agent or mandatary authorized to accept notices and orders.
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'The prescribed registration fee for the purpose of subsection 29(2) of the Act is the amount determined by the formula $2,500 x (A/B)' where A is the prior calendar year's September All-items Consumer Price Index for Canada and B is the September All-items CPI for the calendar year the fee section came into force; 'the fee to be included with an application for registration that is submitted in the calendar year in which this section comes into force is $2,500'; and if the CPI-indexed formula would produce a fee lower than the prior year's fee, 'the fee is instead equal to the fee applicable in that previous year.'
The registration fee mechanism: $2,500 base, CPI-indexed thereafter, no year-over-year decrease
Retrieved HTML (158,602 bytes, HTTP 200), stripped to plain text and read directly in this session. Quoted fragments paraphrase around the formula symbol, which did not render cleanly through HTML-to-text stripping; the $2,500 figures and the no-decrease rule are read directly from the regulation text. No dollar figure for the current calendar year's indexed fee is stated in this article, since that requires a CPI calculation this session did not perform.
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National security review prescribed periods: 'The prescribed period for the purpose of subsection 34(1) of the Act is 60 days beginning on the day after the day on which the Minister is provided with a copy of the application' (extendable by a further 60 days under s.34(2)); 'The prescribed period for the purpose of section 36 of the Act' — the conduct of the review itself, once the Minister decides to review — 'is 180 days beginning on the day after the day on which the Minister decides to review the application' (extendable in further 180-day increments).
The national-security-review timeline, if the Minister of Finance opens one
Same retrieved regulation text. These periods apply only if the Minister decides to review an application for national-security reasons under RPAA s.34 — most applications do not trigger this track, and no fixed statutory timeline governs an ordinary registration decision outside it.
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Safeguarding-of-funds regulations: an account under paragraph 20(1)(a) or (c) of the Act must be provided by an entity referred to in RPAA s.9(a)-(d) or (f)-(h), or a comparably regulated foreign financial institution (s.13); an insurance or guarantee provider under paragraph 20(1)(c) must meet the same entity-type test, must not be affiliated with the PSP, and its proceeds must not form part of the PSP's estate, must be payable to end users as soon as feasible on an insolvency-type event, must survive the PSP's insolvency or restructuring, and the Bank must be notified at least 30 days before any cancellation or termination (s.14); a PSP holding end-user funds must maintain a written safeguarding-of-funds framework including a ledger identifying each end user and the amount of funds held for them (s.15).
Operative detail for two of the Act's three safeguarding options (trust account and insured account); no regulation was found prescribing an account or manner under the Act's third option, paragraph 20(1)(b)
Same retrieved regulation text, read in full. Searched the complete retrieved regulation text for 'prescribed account', 'paragraph 20(1)(b)' and 'trust account' — no provision prescribing an account or manner under RPAA paragraph 20(1)(b) was found, which supports treating that option as not currently operative rather than asserting no such regulation could ever exist.
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'...the prescribed period within which the Bank may refuse to register an applicant is... in the case of a refusal for the reason referred to in paragraph 48(1)(a) of the Act, 45 days beginning on the day after the day on which the period referred to in subsection 29(3) of the Act expires'; requests for review of a refusal or of a notice of intent to revoke must be made within 30 days of notification.
Prescribed periods around refusal and review, illustrating that most RPAA timelines are regulation-set, not stated in the Act itself
Same retrieved regulation text.
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'The Governor in Council may, on the recommendation of the Minister, make regulations for the purposes of this Act, including regulations... establishing a penalty or a range of penalties in respect of a violation up to a maximum of $10,000,000.'
The statutory ceiling on administrative monetary penalties under the RPAA
Same retrieved Act text. This is the outer ceiling Parliament set for regulations establishing AMP amounts, not itself a stated per-violation figure — the Regulations set the operative tiered ranges within this cap; see the SOR/2023-229 ss.47-48 entry below.
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'(1) The range of penalties in respect of a violation, other than one referred to in subsection (2), is (a) up to $1,000,000 in the case of a serious violation; and (b) up to $10,000,000 in the case of a very serious violation.'
The Regulations' operative AMP tiers: each violation is classified serious or very serious against the Regulations' own schedule, with penalty ranges set accordingly
Retrieved regulation text (same 158,602-byte HTML fetch used elsewhere in this article), read directly. S.47(1) classifies each violation under Part 5 of the Act as serious or very serious per the schedule; s.48(1) sets the two ranges. S.48(2) separately sets special daily-accrual amounts ($500/day up to 30 days, $15,000-$1,000,000 beyond) for violations of ss.21, 22(1), 59(1), 60(1)/(2) of the Act specifically — not the general two-tier range and not restated in this article's body for brevity.
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'If the Bank believes on reasonable grounds that a payment service provider has committed a violation, the Bank may... issue and cause to be served on the payment service provider a notice of violation with an offer to reduce by half the penalty set out in the notice if the payment service provider enters into a compliance agreement.' A PSP that does not honour the compliance agreement 'is liable to pay... the difference between the penalty set out in the notice of violation and any portion of the reduced penalty... paid; and an additional penalty specified in the regulations.' The Regulations state: 'For the purpose of paragraph 82(1)(b) of the Act, the additional penalty is equal to the amount of the penalty set out in the notice of violation.'
The compliance-agreement penalty-halving mechanism and the consequence of default
CORRECTED 2026-08-31 (independent review). The statutory halving/default mechanism is from the Act; the specific detail that the additional default penalty equals the original AMP amount was previously attributed to Bank of Canada guidance and described as 'not separately retrieved in this session' — that was wrong. SOR/2023-229 s.50 was in fact retrieved this session (same 158,602-byte HTML fetch used elsewhere in this article) and states the rule directly and verbatim, quoted above. The claim is now sourced to the Regulations, the primary instrument, not to Bank of Canada guidance restating it.
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'For greater certainty, a violation is not an offence and, accordingly, section 126 of the Criminal Code does not apply in respect of a violation.' 'Due diligence is a defence in a proceeding in relation to a violation.'
Same retrieved Act text.
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'No notice of violation is to be issued after the second anniversary of the day on which the Bank becomes aware of the acts or omissions that constitute the alleged violation.'
Same retrieved Act text.
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The Bank must make public the nature of a violation and the name of the PSP once a violation is deemed committed or a notice of decision is served; the Bank of Canada states published notice-of-violation information includes the PSP's name, the nature of the violation, the AMP amount if applicable, the reasons for the notice, and a description of any compliance agreement.
Publication of enforcement outcomes
Statutory publication duty from the Act s.93; the itemized content list is the Bank of Canada's own description of what it publishes.
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The Bank must refuse to register an applicant with no place of business in Canada, and must revoke the registration of a PSP with no place of business in Canada, if the applicant/PSP has committed a violation, is liable for a penalty, and the penalty remains unpaid 30 days after all proceedings on the violation have ended.
A registration/revocation backstop specific to PSPs with no Canadian office
Same retrieved Act text.
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'Retail Payment Activities Regulations SOR/2023-229 RETAIL PAYMENT ACTIVITIES ACT Registration 2023-11-03 Retail Payment Activities Regulations P.C. 2023-1106 2023-11-03'
The Regulations' own registration date, per the regulation's header block
CORRECTED 2026-08-31 (independent review). A prior draft stated the Regulations were 'finalized and published in the Canada Gazette on 22 November 2023' with no source entry backing that specific date. The regulation's own header (same 158,602-byte retrieved HTML used elsewhere in this article) states registration on 3 November 2023 under P.C. 2023-1106 — the primary-source date for when the Regulations were made. (A Canada Gazette Part II publication date of 22 November 2023 is separately stated on Bank of Canada guidance pages already cited elsewhere in this article's sources, but registration and Gazette publication are two distinct steps in the regulatory process, and the article's 'finalized' framing conflated them — the body now cites only the primary-source registration date.)
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The RPAA was assented to on 29 June 2021 and came into force in stages: most of ss.1-10, 12-16, 61, 62(1)(3)(4) and 63 on assent; s.23 (registration required) on 16 November 2024; s.11, ss.28-44, 49, 51, 62(2), ss.64-98 and ss.101-108 (including the registration-application provisions, national-security-review provisions, and Part 5 administration/enforcement) on 1 November 2024; and ss.17-22, 24-27, 45-48, 50 and 52-60 (including ss.17-22's operational-risk and safeguarding requirements, s.25's duty to register, and the registry, refusal and revocation provisions) on 8 September 2025.
The RPAA's staged coming-into-force schedule
Coming-into-force note is on the Act's own consolidated text; corroborated independently by the Bank of Canada's key-milestones page (176,751-byte HTML, stripped and read directly), which states the registration provisions began 1 November 2024 and that risk-management/safeguarding requirements came into force 8 September 2025.
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PSPs performing or planning to perform retail payment activities during the transition period — beginning when s.29 of the Act came into force (1 November 2024) — had a short prescribed window to apply for registration; the Bank of Canada's key-milestones page describes this as a 15-calendar-day window from 1 to 15 November 2024 for individuals and entities already active. The Act's own transition period runs until the day before s.25(1) (the Bank's duty to register) comes into force, i.e. 7 September 2025.
The one-time transitional filing window versus the ongoing 'register before you operate' rule that applies to new entrants today
The 15-calendar-day figure is paraphrased rather than quoted verbatim: the Bank of Canada page's exact sentence contains an HTML-stripping spacing artifact before its closing punctuation that this session could not resolve with confidence, so the figure is stated as fact rather than presented as a direct quotation. This transitional window closed in November 2024 and does not apply to a PSP registering today.
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Part 6 of the Act (Assessment Fees, ss.99-100) is marked, section by section, 'The following provision is not in force' in the Department of Justice's consolidated text of the RPAA, current to 21 June 2026. Separately, the Bank of Canada's retail-payments overview page states it recovers the costs of registration and supervision through 'a one-time registration application fee' and 'annual assessment fees for registered PSPs.'
An apparent gap between the Act's own not-in-force annotation for the annual-assessment-fee provisions and the Bank of Canada's description of annual assessment fees as a current cost-recovery tool
This session could not resolve the discrepancy — no announcement bringing Part 6 into force was found in the retrieved sources. Flagged in the article as a status to confirm with the Bank of Canada directly rather than asserted either way. The Bank of Canada overview page (rps_boc.html in this session's records) was retrieved as HTML and read directly.
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Source types explained in our Methodology.
By Shaun Toh · Director, Digital Payments · Razer