Retail Payments Supervision – Annual Reporting of Retail Payment Activities

Payment service providers (PSPs) that are registered with the Bank of Canada under the Retail Payments Activities Act (RPAA) must submit their annual report by March 31, 2026. In addition, PSPs that are currently on the Bank’s list of applicants may yet become subject to this requirement and should be prepared to submit a report.

This update sets out the three different reporting scenarios for listed applicants, as well as the information required for the annual report.

Who Has to File an Annual Report and When?

Under the RPAA and the Retail Payment Activities Regulations (RPAR), a PSP that performs retail payment activities in a calendar year must submit their annual report in respect of that year no later than March 31 of the following year. While this requirement would seem straightforward once PSPs have been registered with the Bank for an entire year, further interpretation is required for this time of transition and implementation.

First, all PSPs performing retail payment activities prior to September 8, 2025, were required to apply for registration and, while awaiting registration, were required to comply with the RPAA and RPAR, other than reporting obligations. Second, the annual reporting requirement concerns “retail payment activities” whether or not the PSP was registered during that calendar year. Considering this, the Bank says it will enforce the following requirements:

• PSPs that have been registered by the Bank on or before March 8, 2026, must report by March 31, 2026;
• PSPs that are registered by the Bank during the period from March 9, 2026, to March 30, 2026, must report by April 28, 2026;
• PSPs that remain on the Bank’s list of applicants on March 31, 2026, will not be required to file an annual report for 2025, although the Bank may request certain information later.

PSPs should therefore be prepared to file an annual report by March 31 whether they are already registered or currently remain on the list of applicants, as they may not know until March 8 whether the March 31 deadline applies to them. Similarly, after March 8, applicants should be prepared to report by the April 28 deadline in the event that they are registered by March 30.

What is Reported in the Annual Report?

For the most part, the contents of the annual report are set out in the RPAR. The Bank has simplified matters by preparing a form of annual report which PSPs are required to use. Generally, the form asks questions related to the PSP’s compliance with the RPAA and RPAR, including in the areas of:

• Operational Risk and Incident Response
• Safeguarding of End-User Funds (if applicable)
• Ubiquity and Interconnectedness
• Significant Changes/New Activities and Incidents
• Record Keeping
• Financial Metrics
• Other Information the Bank Requires

Notably, information in the annual report is for the calendar year 2025, except for financial metrics, where the PSP is expected to report based on the PSP’s fiscal year-end of that calendar year (for example, as of June 30, 2025, if the entity has a June 30 year-end). The form is available to applicants and registrants now in PSP Connect and registrants must submit their completed annual report by March 31, 2026 (or April 28 if applicable) using PSP Connect. Submitted reports may be amended prior to the applicable deadline using the amendment form available on PSP Connect.

The Bank of Canada’s positions summarized in this update and other information and guidance for PSPs, including a step-by-step guide through the Annual Report, may be found on the Bank's website.

Goodmans monitors legislative and regulatory developments, including guidance from the Bank concerning the RPAA, and we are available to assist our clients in navigating the new supervisory regime. For more information, please contact Brian Empey or any other member of our  Financial Services Regulatory Group.