Bank of Canada Launches Public Enforcement Register for Payment Providers
The Bank of Canada will now publicly disclose RPAA enforcement actions against payment service providers.
The Bank of Canada introduced a public enforcement page under the Retail Payment Activities Act (RPAA), increasing transparency around regulatory action taken against registered payment service providers. The page identifies firms that have violated the RPAA or its regulations, outlines the nature of each violation and any administrative monetary penalty imposed, and retains enforcement records for five years. Enforcement outcomes are also reflected in the public Registry of Payment Service Providers, creating a single reference point for supervisory actions.
The initiative follows the Bank's regulatory notice issued on June 12, 2026, confirming that enforcement decisions would be published after the review process is complete. The retail payments milestones page was subsequently updated on June 30, 2026, confirming that publication of enforcement decisions had commenced.
Key Features of the Enforcement Framework
Enforcement decisions are published only after the applicable supervisory and appeal process has concluded.
Each published record identifies the firm, the nature of the violation and the administrative monetary penalty imposed.
Enforcement records remain publicly available for five years.
Temporary orders may also be published where required under the supervisory framework.
Enforcement Process
The Bank must issue a notice of violation within two years of becoming aware of an alleged contravention.
Payment service providers have 30 days to make representations after receiving a notice.
If no response is submitted, the violation is deemed to have been committed and the full penalty becomes payable.
Where representations are made, the Governor's delegate issues a determination that may be appealed to the Federal Court within 30 days.
Final decisions are published only after the enforcement process has concluded.
Administrative Monetary Penalties
Penalties may reach up to $1 million for serious violations and up to $10 million for very serious violations.
The Bank determines the amount after considering factors such as the potential market impact of the violation, the firm's compliance history and its conduct during supervisory proceedings.
Firms may receive a reduced penalty by entering into a compliance agreement that sets out corrective actions and implementation timelines.
Failure to meet the terms of a compliance agreement may result in additional financial consequences, including payment of the remaining penalty.
Common Areas of Supervisory Focus
Carrying out retail payment activities without registration.
Failure to submit mandatory reports, notices or annual filings.
Failure to notify the Bank of significant operational changes or reportable incidents.
Failure to respond to supervisory information requests.
Weaknesses in operational risk management, incident response or safeguarding of end user funds.
Inadequate record keeping or failure to retain required records for the prescribed five year period.
🚨 What This Signals for the Canadian Payments Sector
The publication of enforcement decisions marks a shift toward greater supervisory transparency under the RPAA. Regulatory outcomes are now visible to financial institutions, business partners, investors and prospective clients, making compliance performance a more prominent consideration in commercial relationships and due diligence.
For payment service providers, the initiative reinforces the importance of maintaining effective governance, timely regulatory reporting and strong operational controls. The public register also offers greater insight into the compliance issues receiving supervisory attention, helping firms assess their own compliance practices against evolving regulatory expectations.
