Refusal or Revocation of Registration under the Retail Payment Activities Act (RPAA)

Publication date: August 21, 2025

This supervisory policy outlines the Bank of Canada’s (the Bank) powers and procedures to refuse to register applicants or revoke the registration of payment service providers (PSPs) based on the criteria established in the RPAA and its associated regulations.

Background

PSPs must be registered with the Bank before performing any retail payment activities. The Bank must register any individual or entity that applies for registration, subject to its powers to refuse applications in certain circumstances, which are set out in sections 35, 37, 48 and 49 of the RPAA. Similarly, the RPAA provides for certain circumstances in which the Bank may or must revoke a PSP’s registration.

The circumstances in which the Bank can refuse an application for registration include:

• The applicant is not a PSP subject to the registration requirements of the RPAA;
• The Minister of Finance (Minister) issues a directive to the Bank to refuse to register an applicant for reasons related to national security or other reasons prescribed in section 40;
• Other reasons for refusal set out in section 48 of the RPAA and prescribed in the regulations.

Similarly, a registered PSP may have its registration revoked by the Bank in certain circumstances, including:

• The registered individual or entity is no longer a PSP subject to the registration requirements of the RPAA;
• The Minister issues a directive to the Bank to revoke a PSP’s registration for reasons related to national security or other reasons prescribed in section 45;
• Other reasons for revocation set out in sections 52 and 55 of the RPAA and prescribed in the regulations.

Each of these circumstances is discussed in this supervisory policy.

When the Bank refuses an application for registration or revokes a PSP’s registration, it must provide notice of the decision made, and the applicant or PSP will have an opportunity to make representations to either the Bank or the Minister, as applicable. These processes are also discussed below.

Refusal of an application for registration under the RPAA

When the RPAA does not apply to the applicant

A central purpose of the application process is for the Bank to determine whether an applicant is a PSP that is subject to the requirements of the RPAA. The RPAA applies to PSPs that perform retail payment activities in Canada or directed at individuals or entities in Canada, subject to certain exclusions. For more information, see the Bank’s supervisory policy on the Criteria for registering payment service providers. If an applicant does not meet these criteria for registration, the RPAA does not apply to that applicant and the Bank will not register that applicant.

An applicant that is refused for this reason is outside the scope of the RPAA. It may continue to operate in its normal course without oversight by the Bank under the RPAA. This determination by the Bank only applies to the applicant’s current operations. It is possible that the applicant might change its operations in the future or begin new operations that would bring it under the scope of the RPAA. In this case, it must apply for registration and become registered before beginning those operations.

Other reasons for refusal by the Bank

Section 48 of the RPAA sets out other reasons for which the Bank may decide to refuse to register an applicant. These reasons include, for example, where the applicant has provided false or misleading information to the Bank or has not responded to a request for information issued by the Bank. A full list of these reasons is set out in Annex 1 of this supervisory policy.

In certain circumstances, the Bank must refuse an application. These circumstances are also set out in Annex 1 of this supervisory policy.

Applicants that are refused for any of the other reasons set out in Annex 1 must not perform retail payment activities in Canada, or directed at individuals or entities in Canada, and may only resume if they become registered with the Bank through a subsequent application. Similarly, refused applicants that did not apply during the transition period (i.e., between November 1, 2024, and September 7, 2025) may not begin performing retail payment activities to which the RPAA applies. These applicants may only begin performing such activities if they become registered with the Bank. An applicant that is refused for any of these reasons may reapply for registration. When reapplying for registration, the applicant is encouraged to address the Bank’s reason(s) for refusal. 

Reasons for refusal by the Minister

The RPAA provides the authority to the Minister to issue a directive to the Bank to refuse to register an applicant for certain reasons, including for reasons related to national security.

For information about refusals directed by the Minister, please see the Department of Finance Canada’s webpage concerning the National Security Review Process under the Retail Payment Activities Act.

Revocation of registration under the RPAA

When the RPAA no longer applies to a PSP

The Bank only registers and supervises PSPs that are subject to the requirements under the RPAA. If a registered PSP changes its operations, such that the RPAA no longer applies to its activities, then the Bank will no longer supervise that PSP and will revoke its registration.

A PSP whose registration is revoked for this reason is not within scope of the RPAA. However, it is possible that the PSP might resume its retail payment activities or begin new retail payment activities that are subject to the RPAA. If this is the case, it must reapply for registration as a PSP and become registered before beginning or resuming those operations.

Other Reasons for revocation by the Bank

Section 52 and subsection 55(1) of the RPAA set out the other reasons for which the Bank may decide to revoke a PSP’s registration. These reasons include, for example, where the PSP is found to have committed one or more violations of the RPAA. A full list of these reasons is set out in Annex 2 of this supervisory policy.

In certain circumstances, the Bank must revoke a PSP’s registration. These circumstances are also set out in Annex 2 of this supervisory policy.

A PSP whose registration is revoked for any of the other reasons set out in Annex 2 must not perform retail payment activities without being registered. These PSPs are expected to cease performing retail payment activities in Canada, or directed at individuals or entities in Canada, and may only resume if they become registered with the Bank again through a subsequent application. A PSP whose registration is revoked for any of these reasons may reapply for registration. When reapplying for registration, the PSP is encouraged to address the Bank’s reason(s) for revoking its registration. 

Reasons for revocation by the Minister of Finance

The RPAA provides certain powers to the Minister to issue a directive to the Bank to revoke a PSP’s registration for reasons related to national security.

For information about revocations directed by the Minister, please see the Department of Finance Canada’s webpage concerning the National Security Review Process under the Retail Payment Activities Act.

Process for refusals and revocations

This section provides an overview of the steps involved in the refusal or revocation of registration under the RPAA.

Refusal under section 48 of the RPAA

Refusal Decisions

When the Bank receives an application for registration, the Bank will review it to ensure it contains all necessary information. Once the Bank has confirmed that all necessary information has been provided, it will deem the application ‘complete’.

For applications submitted after September 8, 2025, the Bank has 45 days from when the application is deemed to be complete to decide to refuse the application.1

As soon as feasible after deciding to refuse an application, the Bank must send to the applicant a notice of refusal. The notice of refusal will set out the Bank’s grounds for refusing the application, as well as an explanation of the Bank’s rationale or analysis that led to the decision.

Prescribed Review

An applicant that does not agree with the Bank’s decision to refuse its application may request a prescribed review of the decision.2 The applicant must request a prescribed review and make written submissions within 30 days of being notified of the refusal. The Bank must decide on the matter within 90 days of when the applicant requests the review, and notify the applicant of the outcome in writing as soon as feasible. For more information regarding the prescribed review process, please see the Bank’s supervisory policy regarding Reviews and appeals.

Publication to list of refused individuals or entities and revoked PSPs

If the applicant does not request a review of the refusal decision within the prescribed 30-day period or pursues a review of the decision and the decision to refuse the application is upheld, the applicant’s application will be refused. At that time, the Bank must add the applicant to the list of refused individuals or entities and revoked PSPs published to the Bank’s website. The applicant’s entry in the list will include the reason(s) for which the application was refused.

Revocation under section 52 of the RPAA

Revocation decisions

The Bank may deem it necessary to revoke a registration at any time. When the Bank decides to revoke a PSP’s registration, it must issue a notice of intent to revoke the PSP’s registration. The notice of intent will set out the reason(s) for which the Bank intends to revoke the PSP’s registration, as well as explanation of the Bank’s rationale or analysis that led to the decision.

Prescribed Review

A PSP that does not agree with the Bank’s intention to revoke its registration may request a prescribed review of the decision.3 The PSP must request a prescribed review and make written submissions within 30 days of being notified of the Bank’s intent to revoke its registration. The Bank must decide on the matter within 90 days of receiving the request for a review, and notify the PSP of the outcome in writing as soon as feasible. For more information regarding the prescribed review process, please see the Bank’s supervisory policy regarding Reviews and appeals.

Publication to list of refused individuals or entities and revoked PSPs

If the PSP does not request a review of the intent to revoke within the prescribed 30-day period or pursues a review of the decision and the intent to revoke the registration is upheld, the PSP’s registration will be revoked. The Bank must add the PSP to the list of refused individuals or entities and revoked PSPs published to the Bank’s website. The PSP’s entry in the list will include the reason for which the application was revoked.

Refusal or revocation due to a directive from the Minister

The RPAA provides the Minister with the power to issue a directive to the Bank to refuse to register an applicant or to revoke a PSP’s registration. For refusals, the Bank will inform the applicant of the Minister’s directive, after which the applicant will have an opportunity to make representations to the Minister. Similarly, for revocations, the Bank will inform the PSP of the Minister’s directive indicating the intent to revoke registration, and the PSP will have an opportunity to make representations. In either circumstance, the Minister is responsible for administering the review process, and instructions for proceeding with the review will be included with the notice provided to the applicant or PSP by the Bank.

Should the refusal or revocation be confirmed through the review process, or a review is not requested, the Bank will notify the applicant or PSP of the refusal or revocation, and the refused or revoked individual or entity will be added to the Bank’s list of refused individuals or entities and revoked PSPs.

Re-registration after refusal or revocation

An individual or entity whose application was refused or whose registration was revoked may apply for registration at any time following refusal or revocation. However, re-registration may be refused if the previous reason(s) for refusal or revocation still apply. For further information, see the Bank’s supervisory policy on Re-registration after refusal or revocation.

Annex 1: Reasons for refusal under the RPAA

The following summarizes the reasons established in the RPAA for which an application for registration may be refused.  

RPAA 48(1)(a)

The Bank may refuse an application if the applicant failed to provide additional information in accordance with subsection 29(3).

RPAA 48(1)(b)

The Bank may refuse an application if the applicant provided false or misleading information.

RPAA 48(1)(c)-(e)

The Bank may refuse an application if FINTRAC has provided information to the Bank which causes the Bank to decide to refuse the applicant’s registration. Specifically:

• The applicant has been found guilty of an offence listed in sections 74, 75 or 76, subsection 77(1) or 77.1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)
• During the 5 years before the day the application was made, a notice of decision or of an imposed penalty in respect of a serious or very serious violation was issued and served on an applicant under subsection 73.15 of the PCMLTFA by the Director of FINTRAC
• The applicant is not registered in accordance with section 11.1 of the PCMLTFA

RPAA 48(1)(f)

The Bank may refuse an application if the applicant has ceased to perform or no longer plans to perform retail payment activities.

RPAA 48(1)(g)

The Bank may refuse an application if the applicant has committed or has been deemed to have committed a violation under the RPAA.

RPAA 48(1) / RPAR 30(b)(i)

The Bank may refuse an application if the applicant failed to pay an assessment or interim assessment that was made against them under section 99 of the RPAA when they were a registered PSP.

RPAA 48(1) / RPAR 30(b)(ii)

The Bank may refuse an application if the RPAA does not apply to the applicant or in respect of any payment functions that they perform or plan to perform.

RPAA 48(2)

The Bank must refuse the application of an applicant that does not have a place of business in Canada, has committed a violation and has unpaid penalties in respect of the violation (and 30 days have elapsed since proceedings in respect of the violation are ended).

RPAA 49

The Bank must refuse the application if the Minister of Finance has issued a directive to refuse the applicant’s registration.

Annex 2: Reasons for revocation under the RPAA

The following summarizes the reasons established in the RPAA for which a PSP’s registration may be revoked. 

RPAA 52(a) 

The Bank may revoke registration if the PSP provided false or misleading information.

RPAA 52(b)-(d)

The Bank may revoke registration if FINTRAC has provided information to the Bank which causes the Bank to decide to revoke the PSP’s registration. Specifically:

• The payment service provider has been found guilty of contravening a provision referred to in section 74, 75 or 76, subsection 77(1) or section 77.1 of the PCMLTFA
• The Director of the Centre, under subsection 73.15(4) of that Act, has caused a notice of a decision or of an imposed penalty to be issued and served on the payment service provider in respect of a violation that was classified as a serious or very serious violation under that Act
• The payment service provider is not registered in accordance with section 11.1 of that Act

RPAA 52(e)

The Bank may revoke registration if the PSP has ceased to perform retail payment activities.

RPAA 52(f)

The Bank may revoke registration if the individual or entity that has applied for registration under section 24 has acquired control of the registered PSP.

RPAA 52(g)

The Bank may revoke registration if the PSP has committed or has been deemed to have committed a violation under the RPAA.

RPAA 52 / RPAR 32(a)

The Bank may revoke registration if the payment service provider has failed to pay an assessment or interim assessment made against it under section 99 of the RPAA.

RPAA 52/ RPAR 32(b)

The Bank may revoke registration if the RPAA no longer applies to the payment service provider or in respect of any payment functions that it performs or plans to perform.

RPAA 55(1)

The Bank must revoke registration if a PSP that does not have a place of business in Canada, has committed a violation and has unpaid penalties in respect of the violation (and 30 days have elapsed since proceedings in respect of the violation are ended).

RPAA 56(1)   

The Bank must revoke a PSP’s registration if the Minister of Finance has directed the Bank to revoke the registration.

Endnotes