Quick answer
RPAA registration means registering with the Bank of Canada as a payment service provider under the Retail Payment Activities Act. You need it if your service lets clients pay, get paid or send money, for example through an e-wallet, money transfers, payment processing or a payment card. This applies to businesses in Canada and to foreign ones serving clients there. A crypto exchange usually does not need it if clients’ money is used only to buy and sell crypto, even when they pay in cash. Such an exchange gets an MSB licence from FINTRAC instead.
If you are building a crypto or payments business in Canada, two registrations come up early. The first is the money services business (MSB) licence from FINTRAC. The second is RPAA registration, often called Bank of Canada registration or, in the market, a PSP licence. Almost every such business needs the first. Whether you need the second depends on what you do with clients’ money. This guide answers the question founders ask most: does my MSB need to register under the RPAA? It gives a clear yes or no for typical business models and then walks through the borderline cases that need a closer look.
RPAA registration vs MSB licence: the Bank of Canada and FINTRAC
The licence from FINTRAC answers the question “What services do you offer?” Transferring money, exchanging currencies, dealing in virtual currency and similar services need this licence and an anti-money-laundering programme. Our guide to the MSB licence in Canada covers that side.
RPAA registration with the Bank of Canada answers a different question: “How do you handle your clients’ money?” The Bank wants payment companies to run reliable systems and keep client funds safe. It looks only at fiat money — money issued by a government, such as Canadian dollars, US dollars or euros.
| MSB licence (FINTRAC) | RPAA registration (Bank of Canada) | |
|---|---|---|
| Main goal | Preventing money laundering and terrorist financing | Reliable payment services and safe client funds |
| Triggered by | Offering one of the listed MSB services | Handling clients’ fiat payments as a service |
| Crypto exchange | Covered | Not covered, unless it adds a separate fiat payment product |
| Key duties | Compliance programme, client checks, reporting | Risk and incident management, safeguarding of client funds, reporting to the Bank |
The MSB licence and Bank of Canada registration overlap but do not replace each other: many payment MSBs need both, while a crypto exchange usually needs only the FINTRAC licence.
What counts as a payment service under the Retail Payment Activities Act
The Retail Payment Activities Act lists five payment functions. Performing even one of them for clients in fiat is what the Act calls a retail payment activity, and it can make your business a payment service provider (PSP).
| Payment function | What it means in practice | Typical example |
|---|---|---|
| Providing or maintaining an account | You keep client accounts used to send or receive money | A payment app or e-wallet |
| Holding funds | Client money stays with you until it is withdrawn or sent on | An e-wallet balance before it is spent |
| Initiating a transfer | You start a transfer when the client asks | A remittance service sending money abroad |
| Authorising or transmitting payment instructions | You approve payments or pass payment messages on | Approving a card payment |
| Clearing and settlement | You work out and settle what each party is owed | Paying merchants their card takings |
A function alone is not enough, though: it must be a payment service you offer in its own right. That is why a crypto exchange holding clients’ fiat for trading does not need to register, as explained below.
Who needs RPAA registration
The Bank’s registration criteria come down to four statements. You must register with the Bank of Canada if all four are true:
- you perform at least one of the five payment functions for clients;
- the money involved is fiat;
- the payment function is a service in its own right, not just a step that supports another business;
- your company has a place of business in Canada (it is incorporated there or has an office, staff or agents there), or it serves and targets clients in Canada from abroad.
In practice, this covers most payment MSBs and the crypto MSBs that add a separate fiat payment product.
| Business model | Why registration is required |
|---|---|
| Money transfers and remittances | You initiate and transmit transfers for clients |
| E-wallet or payment account app | You provide accounts and hold client funds |
| Payment processing for online merchants | You pass on payment instructions and settle with merchants |
| Payment card programme, including crypto-backed cards | You maintain accounts and authorise payments, even when a partner bank issues the cards |
| Currency exchange with client accounts and payouts to third parties | You hold client funds and send transfers |
Who does not need to register: RPAA exclusions and exemptions
The RPAA does not apply, and no registration is needed, in the following cases.
| Situation | Why the RPAA does not apply |
|---|---|
| Crypto exchange where clients pay fiat to buy crypto, keep a fiat balance for future purchases or receive fiat for crypto they sell | The fiat side is part of the exchange service, not a separate payment service |
| Crypto-to-crypto exchange, hosted crypto wallet, crypto transfers | No fiat money moves; no crypto unit has been brought under the Act at the time of writing |
| Cash-only exchange — currency for currency, or cash for crypto at a desk or crypto ATM | No electronic fiat transfer takes place |
| Foreign company with no clients in Canada, or one that does not direct its services at Canada | A foreign provider is covered only if it both serves and targets clients in Canada |
Does a crypto exchange need RPAA registration?
No, not for the exchange itself. For a business registered with FINTRAC as a crypto MSB, exchanging crypto for the client’s own fiat is not a payment service. The Bank’s own example confirms it: a platform where clients deposit fiat, keep fiat balances, buy and sell crypto and withdraw the proceeds does not need to register. The fiat side exists only to serve the exchange, earns no separate income, and clients see the business as an exchange. A balance kept for future purchases is part of that service, and paying sale proceeds into the client’s own bank account does not change the picture. Crypto ATMs and cash OTC desks are outside the RPAA altogether, because no electronic fiat transfer takes place.
Registration comes into play only when fiat becomes a payment product of its own: transfers to other people, a payment card or payouts to merchants. The licence from FINTRAC is needed either way.
RPAA borderline cases: how common business models are treated
The Bank of Canada publishes case scenarios for unclear situations. These are the ones crypto and payment MSBs ask about most.
Crypto payment gateway that pays merchants in fiat
Usually required. Accepting crypto from shoppers and settling merchants in fiat is a payment service in itself: you transmit and settle payments for your merchant clients. If merchants are settled in crypto only, no fiat moves and the RPAA does not apply.
Working as an agent of a registered PSP or through a partner bank
Not required for what you do as the agent of a registered PSP that lists you in its registration. This is known as the agent exemption. Anything you do under your own name for your own clients needs its own registration. Using a licensed bank or provider for the payment rails does not change that.
Money only passes through your account
Still required in most cases. Money you receive with an instruction to send it on straight away is “in transit” rather than held, even if routine processing or anti-fraud checks delay it overnight. That spares you the safeguarding rules for held funds, but sending the money on is a payment function in itself, so registration is still needed.
Business clients only, a free service or a pilot
Still required. B2B payment services are covered, and the Bank has confirmed that registration does not depend on revenue. Registration is required before any payment activity, so a free service or a pilot with real payments needs it from the first transaction.
Where your company and your clients are
A Canadian company needs registration even if most of its clients are abroad. The Act covers every company with a place of business in Canada, so the Bank looks at what you do, not at where your clients live. This matters for Canadian MSBs that serve EU clients who come to them on their own. The EU side follows its own rules alongside your Canadian registrations — for crypto services, the reverse solicitation rules under MiCA.
A foreign company must register if it serves and targets clients in Canada. A licence from another country, a FINTRAC licence as a foreign MSB or a registered Canadian partner does not change this. Targeting is judged broadly: a provider that is well known in Canada may be directing its services there even without Canadian marketing.
Not sure which side your model falls on?
Send us a short description of how fiat money moves through your business, and our consultants will tell you whether RPAA registration applies to it.
Next steps: planning your FINTRAC and Bank of Canada registrations
The easiest moment to get this right is before launch. When you prepare your FINTRAC application, map how fiat money will move through your business. Who holds client balances? Who sends transfers? Will you issue cards or pay out merchants? That map shows which side of the line you are on. If your model sits in one of the borderline cases, a short review before you apply saves months later.
If your model falls on the “required” side, you apply online to the Bank of Canada and can start payment activities once you are registered. Secure your MSB licence first, as the Bank checks your FINTRAC status, and allow a few months for the review. Our guide on how to get a PSP licence in Canada covers what the application asks for, the fee, the timeline and the duties that follow. The application relies on two internal frameworks: one for risk management and one for safeguarding client funds.
Our consultants help businesses obtain an MSB licence in Canada, check planned models against the RPAA and prepare the policies and frameworks for the application. For requirements, timeline and costs on the FINTRAC side, see our step-by-step MSB licence guide.
Frequently Asked Questions
Not formally. The Bank publishes registration criteria, case scenarios and a self-assessment questionnaire, but none of them gives an official decision: each business is responsible for its own assessment. In unclear cases, a written legal analysis of your payment flows is the safest basis for that decision.
No. Registration is only for businesses the Act covers. If it does not cover yours, the Bank refuses the application and the fee is not refunded. So check your model first and apply when your payment flows require it.
Yes, if they both serve and target clients in Canada. A licence in another country or a FINTRAC licence as a foreign MSB does not replace it. A foreign provider with no Canadian clients, or one that does not direct its services at Canada, does not need to register.
Before the new product goes live. The exchange alone stays outside the RPAA, but a card or transfers to other people make you a payment service provider from the first transaction. Because the review takes a few months, apply as soon as the product plan is firm — see our step-by-step application guide.
Not yet. In March 2026 Parliament passed the Stablecoin Act and added the transmission or maintenance of clients’ private keys and tokenised payment instruments to the RPAA payment functions. These rules are not in force yet, so custody and stablecoin projects should plan for them now.
Usually yes, if you offer a payment service to your own clients. The processor’s registration covers its own activity, not yours. You are exempt only for work you do as the listed agent of a registered PSP.
In most cases, yes. If your clients spend crypto through a card and the merchant receives fiat, you maintain accounts and authorise payments in fiat. That makes you a payment service provider, even when a partner bank issues the cards.
No. New providers start their payment services once they are registered, so it pays to apply early: at least 60 days before launch, and ideally more. Starting earlier would be a violation and could stand in the way of the registration itself.
