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Annual Reporting Deadline is in One Week
The deadline for payment service providers (PSPs) registered under the Retail Payment Activities Act (RPAA) to submit their first annual report (the Annual Report) to the Bank of Canada is Tuesday, March 31, 2026.1
While PSPs whose registration applications are approved by the Bank of Canada on or after March 9, 2026 though March 30, 2026 are still required to file an Annual Report, they have been granted an extension until April 28, 2026. For businesses remaining on the list of applicants pending approval as of March 31, 2026, no Annual Report is required for the 2025 reporting year.
The Annual Report covers the reporting period of the 2025 calendar year, and seeks information from PSPs on the following:
- operational risk and incident management;
- end-user funds safeguarding;
- significant change and incident reporting;
- ubiquity and interconnectedness;
- financial information; and
- record keeping.
The Annual Report contains 50 to 95 questions to be answered depending on the scope of the PSPs retail payment activities, so PSPs should anticipate that significant time and effort will be required to properly complete the Annual Report.
The Bank of Canada has published a step-by-step guide to completing the Annual Report, as well as a video information session—both of which provide detailed information with respect to completing and submitting the Annual Report.
Other RPAA-Related Updates: Refused, Revoked and Pending Applications
As of March 23, 2026, the Bank of Canada has included 32 businesses on its published list of refused or revoked applications. Half of those on the list had their applications refused or revoked due to ceasing performance of retail payment activities, or were determined by the Bank of Canada to not be performing activities that fell within the scope of the RPAA.
The second largest category of applicants (eight in total) that were refused registration were those that the Bank of Canada determined were performing retail payment activities, however, the performance of such activities was incidental to activities related to the issuance, exchange or similar of crypto or digital assets (which are not currently within the scope of the RPAA). Consequently, these businesses were not required to register as PSPs under the RPAA.
Two applicants were refused registration on the grounds that they are wholly owned subsidiaries of Canadian banks and consequently subject to prudential regulatory oversight. The Bank of Canada considered these entities to be exempt under Section 9(a) of the RPAA (which states that the RPAA does not apply to banks). These refusals are helpful in understanding the Bank of Canada’s interpretation of this section of the RPAA, and it can be inferred that going forward wholly owned subsidiaries of Canadian banks will not be required to register as PSPs under the RPAA.
For the remaining applicants, other reasons for refusal included: (i) performing retail payment activities that are exempt from the RPAA due to being incidental to non-payment activities or exempt due to being in connection with prescribed transactions in relation to securities; (ii) failing to respond to information requests from the Bank of Canada regarding its RPAA application; and (iii) not being required to register as a PSP due to performing retail payment activities solely as an agent for its affiliate.
Although not included in the Bank of Canada’s list of refused or revoked registrations, on February 17, 2026 the Bank of Canada announced that it issued a temporary compliance order to a PSP to immediately cease performing any retail payment activities, stating that it “failed to safeguard end-user funds in its possession, and caused a significant shortfall in end-user funds to accrue.” On February 27, 2026, the Bank of Canada issued a revised compliance order authorizing the PSP to recommence retail payment activities, subject to the limitations of the order, under the supervision of a monitor appointed by the Ontario Superior Court of Justice under the Companies' Creditors Arrangement Act (Canada).
The Bank of Canada continues to work through a vast number of pending applications. At the time of writing, about 900 applicants continue to await approval of their registration application from the Bank of Canada.
Footnote
1. See Section 21 of the RPAA and Sections 18 & 19 of the regulations thereunder.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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