INTRODUCTION
Attention PSPs regulated under the RPAA - we have information we know many of you have been eagerly anticipating ⭐
The Bank of Canada (BOC) has announced new resources regarding Annual Reporting.
REMINDER - Annual Reporting for all registered PSPs must be submitted prior to March 31, 2026. And we are here to pass along to you everything you need to know!
Note, although reporting functionality is not yet live in PSP Connect, the BOC is encouraging PSPs to review their resources (listed below) in advance to help clarify the process.
Pro-tip ⭐ DM us to get in touch with one of our RPAA experts for extra assurance that you understand your obligations.
But for now, let’s discuss what resources are currently available to you, to get you on the path of completing your FIRST annual report like a superstar.
Available Resources via the BOC
🟠 Recorded Information Sessions
https://www.youtube.com/watch?v=6GOa8YskBPU
This information session hosted by the BOC is an ABSOLUTE MUST WATCH video resource designed to help PSPs understand and confidently prepare their 2025 Annual Report ahead of the March 31, 2026 deadline.
As your resident RPAA experts, we all agree that the information in this session is vital and that many of you will benefit from reviewing (covering many topics you have asked us about!)
The information session walks PSPs through what to expect during Annual Reporting and includes the following topics:
🌟 Overview of Annual Reporting Requirements
🌟 Who must submit the Annual Report
🌟 Preparing for submission
🌟 Timelines for annual reporting
🌟 A step-by-step walkthrough of PSP Connect annual reporting sections, including how to access, complete, submit, and amend the Annual Report form
🌟 Helpful resources, guidance materials, and where to get support
Key Highlights from this session:
The Bank has communicated that the reporting form will be available in PSP Connect the week of February 2nd, 2026.
All PSPs registered by March 30th, 2026 must complete the 2025 annual report.
PSPs that become registered between March 9th and March 30th 2026 will have an extension until April 28th, 2026 to submit the annual report (if needed); everyone else is required to submit the annual report by the regular deadline of March 31st, 2026.
Prior to accessing the annual report form, each PSP is required to confirm their registration information is accurate or amend if required.
After submitting the annual report, and prior to March 31st 2026, PSPs are able to make an amendment to their submitted annual report by accessing PSP Connect and selecting the annual reporting section. PSPs can select ”View Details”, and then select “Submit an Amendment”.
🟠 A Step-by-Step Guide to Annual Reporting
The BOC published a comprehensive guide that gives you a step-by-step account of what questions will be included as part of the annual reporting form.
Reviewing and preparing answers for the annual report in advance will help during submission. PSPs are not required to complete the entire report at once, and are able to save their progress and return later to continue. The questions within the annual report are dynamic and will adjust based on how the PSP responds to earlier questions.
Key Questions from the step-by step guide:
Questions related to risk management and incident response, including if the framework was approved during the 2025 calendar year.
Questions related to measures in place during the calendar year 2025.
Questions surrounding how third party service providers were assessed in 2025
Questions regarding the means of how the PSP is safeguarding funds (in trust vs. insurance or guarantee).
Questions around the max value of end-user funds held and a month-by-month average.
Question on an estimated of the total value of EFTs broken down by payment method (for example card issuance, card acceptance, direct credit or direct debit, e-money or digital wallet, international remittance, Other).
Financial Information questions including the PSPs total revenue, operating expenses, profit or loss, total assets, total liabilities and total equity.
🔶🔶 Now, if you are keen and want to keep reading about these important updates, keep reading below! Or, if you are tired or strapped for time and would like one of our RPAA experts to support you, reach out to us today via DM or email contactus@theamlshop.ca
🟠 Information about annual reporting of retail payment activities metrics
If you are a registered PSP, understanding the reporting metrics required is critical for maintaining compliance. Fortunately, the Bank of Canada has clarified reporting requirements under the RPAA and the expected associated metrics. We have provided a summary below, but still encourage you to review the official document via the BOC here https://www.bankofcanada.ca/2024/10/annual-reporting-of-retail-payment-activity-metrics/
What needs to be reported?
The Bank endeavours to monitor the "ubiquity and interconnectedness” of the payments ecosystem. Thus, PSPs must report on four key quantitative metrics:
Fund Holding
💲The total value of end-user funds held.
A PSP holds end user funds if it keeps funds of a payer or payee at rest and pending a future withdrawal or transfer. This includes when the PSP is awaiting further instructions prior to processing the transfer, and when the instructions are not for the immediate transfer and instead for a future transfer date.
Examples of when a PSP will hold funds include:
PSP receives payer funds and has not received instructions to transfer or is awaiting further instructions prior to processing the transfer to the payee.
PSP holds funds as a balance or in a wallet, until an end-user withdraws or transfers the funds.
PSP receives funds and instructions to transfer but the transfer date is dated in the future and the PSP is considered to be holding the funds until the future date arrives.
Transaction Volume
💸 The number and value of Electronic Funds Transfers (EFTs)
End-Users
👥 Total number of end users served
PSP Reach
💳 The number of other PSPs you provide services to.
Why this matters
The Bank of Canada uses these metrics to:
✨ Prioritize Supervision: Applying a risk-based approach to oversight.
✨ Enforcement: Determining proportionate actions or including administrative monetary penalties for non-compliance.
✨ Insights: Monitoring broader trends and issues in the retail payment space.
Compliance Tip ✅ PSPs are expected to take "all reasonable steps" to ensure data accuracy. Providing false or misleading information is considered a violation under the RPAA.
🟠 Supervisory Policy on Annual Reporting
The BOC has also recently highlighted to PSPs that they should revisit the BOC’s Supervisory Policy on annual reporting.
Below we have prepared a quick summary of the key supervisory policy points when it comes to annual reporting, however we encourage you to read the BOC’s full supervisory policy here https://www.bankofcanada.ca/2024/10/annual-reporting/
Key Highlights:
Submission Deadline
The annual report must be submitted via PSP Connect by March 31st, each year - starting March 31st, 2026.
Reporting Scope
Reports must cover the previous calendar year’s activities and financial metrics should reflect the PSP’s most recent fiscal year-end.
What your report should cover:
The Bank will assess performance across several areas, including:
✨ Operational risk management and incident response frameworks
✨ Holding and safeguarding of end-user finds
✨ Ubiquity and interconnectedness (see retail payments activities metrics above for more details ☝️)
✨ Record Keeping Practices
✨ Financial Metrics
✨ Any other information the Bank requires for its supervision of PSPs
Data Integrity
Remember, providing false or misleading information is strictly prohibited under Section 61 of the RPAA. It is also possible that the Bank may request follow-up information after a report is filed to verify compliance. Be accurate in all reporting...trust us, it matters.
Why reviewing the Supervisory Policy matters:
The BOC’s reporting structure supports a risk-based approach to supervision. A main objective of the RPAA is to ensure that Canada’s payment ecosystem remains reliable, transparent and secure for all end-users. Your business must stay up to date on the supervisory policy in order to fulfill its compliance obligations.
Compliance Tip ✅: Be proactive and review the full RPAA and RPAR guidelines to ensure your internal record-keeping aligns with the questions in PSP Connect. This will save you headaches (and extra time) at reporting time. If you need one of our RPAA experts to help distill what you need to know to make your documents the best they can be - we have worked on dozens of RPAA engagements and can help your business navigate this.
CONCLUSION
Annual Reporting is coming. Our advice is to stay as informed as possible, so you can remain diligent, get ahead of any potential mishaps and eliminate compliance issues in your reporting.
Our RPAA experts are on stand by to help you with all measures of RPAA compliance - including understanding Annual Reporting.