Bank of Canada restates the RPAA reporting calendar for PSPs

The reminder applies to registered PSPs, but its commercial relevance extends to applicants, acquirers and investors. Product teams adding a new payment function, operations teams replacing a critical provider, data teams moving storage locations and corporate teams changing ownership all need to feed one reporting calendar. For a buyer, the target's current PSP Connect records and open reporting obligations become part of the transaction baseline.

The updated policy gives a useful example: adding the holding-of-funds function through a new third-party provider can require both an update to registration information and a separate significant-change or new-activity notice. Each filing remains a separate requirement. The same discipline applies to ownership. Where section 24 requires a new application, all relevant changes can be reflected in that application, covering the information that would otherwise sit in sections 59 and 60 change notices.

Build RPAA classification into the company's normal product, vendor, data and transaction approvals. Every change request should identify the payment function, effect on operational risk and safeguarding, registration data affected, required notice, owner and submission date before implementation is approved.

For acquisitions, start the section 24 workstream early enough for the target to be re-registered before closing. The deal timetable, ownership disclosures, operating model and safeguarding plan should describe the same post-completion business.