Compliance burdens for payment service providers under final Retail Payment Activities Act regulations

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On November 22, 2023, the final regulations to the Retail Payment Activities Act (RPAA) were released. Changes from the draft regulations released earlier this year are minimal, and payment service providers (PSPs) should begin to prepare for the significant compliance requirements once the regime comes fully into force.

The window for PSPs to submit applications to the Bank of Canada opens on November 1, 2024. PSPs applying for registration after the window closes on November 16, 2024, will be unable to perform their retail payment activities for at least two months during the pendency of the review process.

Notable changes to the requirements under the final regulations touch on the following areas:

  • incident restoration system testing
  • safeguarding of funds (SOF) account changes and insolvency reviews
  • risk management system testing
  • independent audits
  • application information on end-user funds

The full risk management and funds safeguarding requirements will come into force on September 8, 2025.

For our full analysis of the final RPAA regulations, please read the Osler Update.