Retail Payment Activities Act (RPAA)
The Retail Payment Activities Act is Canada’s framework requiring payment service providers to register with the Bank of Canada and meet operational risk and end-user fund requirements. RPAA registration is separate from, and additional to, FINTRAC registration as a money services business.
Also called: Canada RPAA · retail payment activities
The RPAA brings payment service providers that perform retail payment activities in Canada under supervision by the Bank of Canada. It is not an anti-money-laundering statute. Its subject is operational reliability and the protection of end-user funds: a registered provider has to maintain a risk management and incident response framework, report incidents, and hold end-user funds in the manner the Act requires.
Registration under the RPAA is a registration rather than a license. The Bank of Canada supervises a registered provider against those obligations; it does not approve a business model the way a licensing authority does.
A provider based outside Canada can be caught where it performs retail payment activities for end users in Canada, so the question is where the customers are, not where the company is incorporated.
In practice
RPAA registration with the Bank of Canada and FINTRAC registration as a money services business are two obligations under two statutes with two different purposes. A business may need both, holding one does not imply the other, and neither is an answer to a regulator asking about the other.
Example
A UK fintech offers a wallet to customers in Ontario and moves money between them. It is performing retail payment activities for end users in Canada, so the RPAA is in scope. If its activity also meets the definition of a foreign money services business, FINTRAC registration applies as well — separately, and on its own timetable.
Commonly confused with
| Term | How it differs |
|---|---|
| FINTRAC | FINTRAC administers Canada’s AML regime and registers money services businesses; the RPAA is supervised by the Bank of Canada and covers operational risk and end-user funds. |
See also
- FINTRACCanada’s financial intelligence unit and anti-money-laundering supervisor. Money services businesses must register with FINTRAC before operating in Canada, report prescribed transactions to it and are examined by it — but FINTRAC issues no license and grants no permission to move money.
- Payment Service ProviderA payment service provider, or PSP, is a firm that moves payments for merchants or consumers. In UK and EU payment services law it is also a defined umbrella term covering several kinds of regulated provider, and Canada defines it separately again under the Retail Payment Activities Act.
- Money Services BusinessA money services business is a category in US federal law under the Bank Secrecy Act, covering seven capacities: dealer in foreign exchange, check casher, issuer or seller of money orders or traveler’s checks, provider of prepaid access, seller of prepaid access, money transmitter, and the US Postal Service.
- Foreign Money Services BusinessA foreign MSB is a money services business located outside the United States that does business wholly or in substantial part within the United States, and must therefore register with FinCEN. Canada uses the same term for a separate status of its own.
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Regulatory information checked: 22/Sep/2026