A Plain-English Guide for Canadian Businesses

Why Canadian regulation matters when you choose a payments provider.

Most Canadian businesses don't know who actually regulates their payment processor. And many of the biggest names in Canadian payments operate in regulatory grey zones. Here's why that should worry you — and what changed in 2024–2026.

The hook: who regulates your payment processor?

Quick test. Without looking it up, can you answer these about your current payment processor?

If you can't answer those, you're not alone — and that's actually the problem. For decades, payment service providers in Canada operated under a patchwork of provincial securities rules, FINTRAC anti-money-laundering rules, and card network rules — but no single federal regulator looked at the actual safety and operational soundness of the processor itself. That changed.

What changed: the Retail Payment Activities Act

The Retail Payment Activities Act (RPAA) is Canada's first dedicated federal supervisory regime for payment service providers. It was passed into law in 2021, and the registration regime came into effect in November 2024. As of 2026, the Bank of Canada actively supervises registered PSPs.

Under the RPAA, any business that performs retail payment activities in Canada — including merchant acquiring, money transfers, holding funds for users, and FX in connection with payments — must register with the Bank of Canada and meet specific operational, financial, and risk-management standards.

Important: Many payment providers that were operating in Canada before November 2024 have not registered. Some are operating illegally. Some are still working through the process. Some are arguing they don't fall under the regime. As a customer, the question to ask is: is my processor a registered PSP, and can I see their entry in the public registry?

What RPAA registration actually means for you

This is the part most coverage skips. Registration under the RPAA isn't a sticker you put on your website — it imposes substantive ongoing obligations on the registered entity:

1. End-user fund safeguarding

Registered PSPs must safeguard end-user funds. In practical terms, that means your customers' money — between when their card is charged and when it lands in your operating account — must sit in segregated accounts at federally regulated Canadian banks, ring-fenced from the PSP's operational funds. If the PSP becomes insolvent, those funds can't be touched by general creditors.

Why this matters: Without a safeguarding obligation, in-flight funds at an unregulated processor are general creditor claims. If the processor fails, your customers' money is gone, and you may be on the hook to make them whole.

2. Operational risk management standards

Registered PSPs must maintain documented operational risk management frameworks — incident response plans, business continuity plans, third-party risk management, technology resilience standards, and documented controls. The Bank of Canada reviews these and can require improvements.

Why this matters: An unregulated processor can have whatever level of operational maturity they want — including very little. A registered PSP has a baseline, externally enforced, and audited.

3. Incident reporting

Registered PSPs must report material operational incidents to the Bank of Canada within strict timelines. This includes outages, data breaches, fraud events above thresholds, and any incident that materially affects payment flows.

Why this matters: Regulator-mandated incident reporting drives prevention. PSPs that have to report are more incentivized to invest in not having incidents.

4. Change-in-control notifications

Registered PSPs must notify the regulator of material changes in ownership or control — preventing unsupervised acquisitions of payment infrastructure by parties who shouldn't be operating it.

5. Annual reporting and ongoing supervision

Registered PSPs file annual reports with the Bank of Canada disclosing transaction volumes, safeguarded fund balances, incident summaries, and risk management updates. The Bank of Canada uses this for ongoing supervision and can examine PSPs at any time.

Plus: FINTRAC MSB registration

Separately, payment providers that handle cross-border transfers, FX, or virtual currency must also register as Money Services Businesses with FINTRAC — Canada's anti-money-laundering and anti-terrorist-financing regulator. This brings additional obligations: customer due diligence, ongoing monitoring, suspicious transaction reporting, and large-cash-transaction reporting.

RPAA + FINTRAC together is the Canadian equivalent of the regulatory standing you'd expect from a bank — minus the legacy infrastructure of a bank.

Why this matters in plain terms

Here's the question worth asking your finance and legal team: what protection do we lose if our payment processor is unregulated?

Novobill's status

Novobill Ltd. is a registered Payment Service Provider with the Bank of Canada under the Retail Payment Activities Act.

  • Entity ID: RPS0014803
  • Status: Registered
  • FINTRAC MSB: Registered

You can verify this independently in the Bank of Canada's public registry of registered PSPs.

A due diligence checklist your team can use

Whether you ultimately choose Novobill or not, your finance and legal team should be asking your payment processor — current or prospective — the following:

  1. Are you registered with the Bank of Canada under the RPAA? If yes, what's your Entity ID? Can you point us to your entry in the public registry?
  2. Are you registered with FINTRAC as an MSB? If you handle cross-border or FX, this is required.
  3. Where are end-user funds held between authorization and settlement? Specifically: which Canadian bank, what type of account, and how is segregation maintained?
  4. What's your safeguarding model? Trust account? Designated bank account? What's the legal basis for ring-fencing?
  5. Who is your designated MLRO? When was your last AML compliance assessment?
  6. What's your incident response and reporting framework? What incidents in the last 12 months were reported to regulators?
  7. What audits do you maintain? PCI DSS level, SOC reports, ISO certifications.
  8. What happens to in-flight funds if you become insolvent? Get this in writing.

If your current processor can't or won't answer these, that's the answer.

The bottom line

For most Canadian businesses, payment processing is the largest operating expense after payroll, and the largest single concentration of customer trust. It's the wrong place to optimize for "I've heard of them" or "the salesperson was nice." It's the right place to optimize for who's regulated, where the funds are, and what protection you have if something goes wrong.

Novobill is built around the answer being: yes, we're regulated; here's exactly where the funds are; here's the protection you have. That's the foundation. Everything else — the API, the pricing, the support — sits on top of that.

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