Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to registration with the Bank of Canada, including banking and payment rails.
Get a payment license in Canada.
Canada has no payment licence. It has two registrations, and most payment businesses need both: registration with the Bank of Canada under the Retail Payment Activities Act, and money services business registration with FINTRAC for anti-money-laundering supervision. Neither imposes a capital requirement. What the Act does impose is section 20 safeguarding - end-user funds held in trust in a dedicated account, or in a prescribed account backed by insurance or a guarantee, with no right of set-off and a ledger of each end user's balance struck at the end of every day. The Bank has supervised payment service providers since 8 September 2025 and reports close to 1,500 of them.
27 yrs
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60+
in-house specialistsspecialists
400+
Licenses obtainedlicenses obtained
Updated
Canada in brief
Two registrations, no capital, and a safeguarding rule written in detail.
Canada asks for registration twice and licenses nothing. The Retail Payment Activities Act puts payment service providers under the Bank of Canada, and registration turns on four tests that must all be met: performing one or more of the five payment functions, as a service or business activity that is not incidental to another service or business activity; performing them in relation to electronic funds transfers; having a place of business in Canada, or directing retail payment activities at end users in Canada and performing them for those end users; and falling outside the exclusions. Those exclusions matter as much as the tests. Sections 6, 7 and 9 take out banks, credit unions and certain provincially regulated institutions on an entity basis, and merchant-issued closed-loop instruments, eligible financial contracts, securities transactions, ATM cash withdrawals, designated payment systems and internal transfers between affiliated entities on an activity basis. Beside it runs the second registration: money services business registration with FINTRAC for foreign exchange dealing, remitting or transmitting funds, money orders and traveller's cheques, virtual currency, crowdfunding platform services, armoured car services, cheque cashing and private ATM acquiring.
Neither regime asks for capital. What section 20 asks for instead is safeguarding: a provider holding end-user funds holds them in trust in a dedicated account, or in a prescribed account together with insurance or a guarantee equal to the amount held, and no right of set-off or compensation may be asserted against that account. The regulations add the detail - an account provider meeting specified prudential standards, an unaffiliated insurer or guarantor, and a ledger identifying each end user and their fund balance maintained at the end of each day - and the Bank's guidance says plainly that deposit insurance alone is not sufficient, because it protects against the account provider's insolvency and not the provider's own. The registration fee is $2,500, indexed to inflation; the annual assessment fee has not been set. The annual report to the Bank falls due no later than 31 March. On 8 September 2025 the Bank announced it supervises close to 1,500 payment service providers. FINTRAC charges no fee, registration is valid for two years, and most complete applications are processed within three months.
Two registrations, no licence. The Retail Payment Activities Act registers payment service providers with the Bank of Canada on four cumulative tests, with entity and activity exclusions in sections 6, 7 and 9. FINTRAC registers money services businesses separately. Neither regime sets a capital requirement.
Section 20: end-user funds in trust in a dedicated account, or a prescribed account plus insurance or a guarantee, no set-off, a daily per-end-user ledger and an annual report by 31 March. $2,500 to register, indexed; FINTRAC free, valid two years. Close to 1,500 providers supervised since 8 September 2025.
The routes
Bank of Canada registration, FINTRAC registration - usually both.
The two regimes answer different questions: the Bank of Canada looks at operational risk and end-user funds, FINTRAC at money laundering and terrorist financing. Which of them applies is settled before anything is filed.
Bank of Canada registration under the RPAA, and FINTRAC MSB registration.
01 - RPAA REGISTRATION
Payment service provider, Bank of Canada
Registration under the Retail Payment Activities Act, required before any retail payment activity is performed under section 23. Section 25 obliges the Bank to register an applicant subject to the exceptions, and the Minister runs a national security review under sections 32 to 35.
Registration under the Retail Payment Activities Act, required before any retail payment activity is performed under section 23. Section 25 obliges the Bank to register an applicant subject to the exceptions, and the Minister runs a national security review under sections 32 to 35.
- ✓Four cumulative tests, and the exclusions in ss. 6, 7 and 9
- ✓No capital or net-worth requirement
- ✓Safeguarding under section 20 where end-user funds are held
- ✓Registration fee $2,500, indexed to inflation
- ✓Annual report to the Bank by 31 March
- ✓Annual assessment fee not yet set
02 - FINTRAC MSB
FINTRAC - no feeMoney services business registration
Registration with FINTRAC for foreign exchange dealing, remitting or transmitting funds, money orders and traveller's cheques, virtual currency, crowdfunding platforms, armoured car services, cheque cashing and private ATM acquiring - with a foreign business registering as an FMSB before it operates.
FINTRAC: no fee, valid two years, most complete applications processed within three months; a foreign MSB names a Canadian representative.
- ✓No registration fee at all
- ✓Valid for two years, renewed before expiry
- ✓Most complete applications processed within three months
- ✓Compliance programme, compliance officer, client identification
- ✓STR, LCTR, LVCTR and EFT reporting obligations
- ✓A designated Canadian representative for a foreign MSB
Costs and timelines are confirmed for your case before any work begins. The RPAA fee is $2,500 indexed, FINTRAC charges nothing, and the annual assessment fee under the RPAA has not been set - the safeguarding account, insurance and Canadian substance are itemised in your quote.
Why Canada
No capital, a duty on the regulator to register, and a real instant rail coming.
Canada opened its payments regime in September 2025 and already supervises close to 1,500 providers. The cost of entry is a fee and a safeguarding build, not a capital raise.
✓
No capital requirement
Neither the Retail Payment Activities Act nor the anti-money-laundering statute imposes a capital or net-worth figure on a payment service provider, a money services business or a foreign one.Neither regime sets a figure.
✓
Registration, not discretion
Section 25 says the Bank must register any individual or entity that applies, subject to the exceptions. That is a different starting point from a licence granted at a supervisor's discretion.Section 25 binds the Bank.
✓
Safeguarding written out in full
Section 20 and the regulations set the account, the insurance or guarantee, the ban on set-off and the daily per-end-user ledger. You build to a text rather than to a supervisor's expectation.Section 20 and the regulations.
✓
A foreign provider can register
A provider outside Canada that directs retail payment activities at persons in Canada registers under the Act. There is no residency or local-office requirement attached to it.Register without a local office.
✓
Close to 1,500 providers
The Bank's own figure on 8 September 2025, the day registration became a precondition of performing retail payment activities. The market is not a pilot.The Bank's own September 2025 count.
✓
The Real-Time Rail
Payments Canada's instant exchange, clearing and settlement system is scheduled to launch in the fourth quarter of 2026, with by-laws and rules approved and industry testing under way.Launching in Q4 2026.
How it compares
How Canada differs from other routes.
Canada charges the least to enter and asks the most about how you hold other people's money. The honest comparison is below.
Canada vs other jurisdictions
| Feature |  Canada | Other jurisdictions |
|---|---|---|
| Regime | Two registrations, no licence | Licences almost everywhere else |
| Capital | None under either regime | $30,000 in Cayman · EUR 350,000 for a UK EMI |
| Safeguarding | Trust account or insurance (s. 20) | Barred in Bermuda · no rule in Cayman |
| Cost to enter | $2,500 once · FINTRAC free | CI$20,000 a year in Cayman |
Regime
CanadaTwo registrations, no licence
Other jurisdictionsLicences almost everywhere else
Capital
CanadaNone under either regime
Other jurisdictions$30,000 in Cayman · EUR 350,000 for a UK EMI
Safeguarding
CanadaTrust account or insurance (s. 20)
Other jurisdictionsBarred in Bermuda · no rule in Cayman
Cost to enter
Canada$2,500 once · FINTRAC free
Other jurisdictionsCI$20,000 a year in Cayman
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Canada | RPAA and FINTRAC registration | 15% federal net · 9% small | No capital · s. 20 safeguarding |
 United States | State MTLs and FinCEN | 21% federal plus state | State by state, bonding |
 Bermuda | Money service business (BMA) | 15% above EUR 750M | No client money held (s. 11(3)) |
 United Kingdom | EMI or PI (FCA) | 25% · 19% small | EUR 350,000 EMI · 3-month clock |
CanadaLicense typeRPAA and FINTRAC registration
Taxation15% federal net · 9% small
RequirementsNo capital · s. 20 safeguarding
United StatesLicense typeState MTLs and FinCEN
Taxation21% federal plus state
RequirementsState by state, bonding
BermudaLicense typeMoney service business (BMA)
Taxation15% above EUR 750M
RequirementsNo client money held (s. 11(3))
United KingdomLicense typeEMI or PI (FCA)
Taxation25% · 19% small
RequirementsEUR 350,000 EMI · 3-month clock
Before you apply
Requirements for the two Canadian registrations.Requirements for registration.
The Act sets the tests, the exclusions and the safeguarding duty; the regulations set the accounts, the ledger and the reporting. The checklist below is what a passing file contains.
01
The four cumulative RPAA tests applied to the actual product: a payment function performed as a service that is not incidental to another service, in relation to electronic funds transfers, with a place of business in Canada or activity directed at and performed for end users in Canada.
02
The exclusions in sections 6, 7 and 9 checked before filing - banks, credit unions and certain provincially regulated institutions on an entity basis, and closed-loop merchant instruments, eligible financial contracts, securities transactions, ATM cash withdrawals, designated payment systems and intra-group transfers on an activity basis.
03
No capital: neither the Retail Payment Activities Act nor the anti-money-laundering statute sets a capital or net-worth figure, so the balance sheet question is about safeguarding rather than about a minimum.
04
A safeguarding framework under section 20 where end-user funds are held: trust in a dedicated account, or a prescribed account together with insurance or a guarantee equal to the amount held, with no right of set-off or compensation asserted against it.
05
An account provider meeting the prudential standards of regulation 13, or a foreign financial institution prudentially regulated under a comparable regime for capital, liquidity, governance, supervision and risk management.
06
An insurer or guarantor unaffiliated with the provider under regulation 14(1), for a value equal to or above the end-user funds held and payable for the benefit of end users as soon as feasible following an insolvency event.
07
A ledger identifying each end user and their fund balance, maintained at the end of each day under regulation 15(2)(b) - the Bank's guidance adds that deposit insurance alone is not sufficient.
08
An operational risk and incident response framework, incident reporting without delay, and notice of a significant change at least five business days before it takes effect.
09
The section 29 application with the $2,500 registration fee, disclosing the organisational structure, the retail payment activities, the number of end users, the risk management framework, the safeguarding methods, third-party service providers, agents and mandataries - and the annual report to the Bank no later than 31 March.
10
FINTRAC registration with a compliance programme, a compliance officer, client identification and beneficial ownership, ongoing monitoring, record keeping and the reporting obligations, plus a designated Canadian representative if the business is a foreign money services business.
01
The four cumulative RPAA tests applied.
02
Exclusions in sections 6, 7 and 9 checked.
03
No capital under either regime.
04
Safeguarding under section 20.
05
Account provider meeting regulation 13.
06
Unaffiliated insurer or guarantor (reg. 14(1)).
07
Daily per-end-user ledger (reg. 15(2)(b)).
08
Incident and significant-change reporting.
09
Section 29 application and $2,500 fee.
10
FINTRAC programme, officer and reporting.
Reflects the Retail Payment Activities Act (S.C. 2021, c. 23, s. 177), the Retail Payment Activities Regulations SOR/2023-229, the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and the Bank of Canada's supervisory guidance, as of 2026.Retail Payment Activities Act (S.C. 2021, c. 23, s. 177); Retail Payment Activities Regulations SOR/2023-229; PCMLTFA; Bank of Canada guidance.
How it works
From first call to the Bank of Canada registry.
01
Scope and exclusions
The four RPAA tests, the exclusions in sections 6, 7 and 9, and the FINTRAC activity list applied to the product - route and budget fixed in writing.Four tests plus ss. 6, 7 and 9.
02
Structure and accounts
Canadian entity or foreign registration decided, the safeguarding account opened with a provider meeting regulation 13, insurance or guarantee arranged where used.Safeguarding account and insurance.
03
The application file
Section 29 disclosure, risk management framework, safeguarding methods, third-party providers, agents and mandataries - with the $2,500 fee.Section 29 disclosure; $2,500 fee.
04
Review and screening
The Bank confirms completeness and decides, the Department of Finance runs the national security screening - plan on four to eight months end to end.Bank decision; security screening.
05
Registry and reporting
Entry in the public registry of payment service providers, FINTRAC registration renewed every two years, and the 31 March annual report calendared.Listed; annual report by 31 March.
Quick facts
RegulatorsBank of Canada · FINTRAC
LawRetail Payment Activities Act · SOR/2023-229
TypeRegistration, not a licence
CapitalNone
SafeguardingTrust, or account plus insurance (s. 20)
Fees$2,500 indexed · FINTRAC free
Timeline4-8 months realistic
Corporate tax15% federal net · 9% small business
Registration has been a precondition of performing retail payment activities since 8 September 2025, and the Bank began publishing notices of violation in June 2026. The Real-Time Rail is scheduled to launch in the fourth quarter of 2026.
Your Canada desk
Run from our North America desk.
Prifinance - North America desk
London · coordinating Canadian mandates
7 Bell Yard, London
01
Scoping the two regimes
The four RPAA tests and the FINTRAC activity list applied to your product, with the exclusions in sections 6, 7 and 9 checked before a single form is opened.Tests and exclusions before any form.
02
Canadian entity where it helps
Neither regime requires local incorporation, but a Canadian entity changes banking and tax. We set out both routes with the costs attached.Optional; changes banking and tax.
03
The safeguarding build
Trust account or prescribed account with insurance, the unaffiliated insurer under regulation 14(1), and the daily per-end-user ledger designed with your ledgering system.Account, insurance, daily ledger.
04
Filing and reporting
The section 29 application, the national security review, incident reporting without delay, significant-change notice five business days ahead, and the 31 March annual report.Section 29; 31 March annual report.
We also have offices in
Tallinn
Estonia
Roseni 13
Vilnius
Lithuania
Gedimino pr. 2
Prague
Czech Republic
Vlkova 532/8, Žižkov
Dubai
UAE
33 Level, Al Saqr Business Tower
Madeira
Portugal
Rua da Alegria 31, 1F
Budapest
Hungary
Korányi Sándor u. 4
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of payment companies in Canada.
A federal rate that steps down from 38% to 15%, a 9% small-business rate inside the business limit, provincial tax on top, and 25% withholding on payments leaving the country.
Federal corporate tax
The basic rate is 38%, 28% after the federal tax abatement, and 15% as the net general rate after the general tax reduction. Zero-emission technology manufacturers pay 7.5%.Abatement, then general reduction.
Small business rate 9%
A Canadian-controlled private corporation pays 9% on active business income within the small business deduction, or 4.5% for qualifying manufacturers.Within the business limit.
The business limit
$500,000 in most provinces and territories, with Nova Scotia at $700,000 and Prince Edward Island and Saskatchewan at $600,000. Income above the limit falls to the general rate.$500,000 in most provinces.
Provincial and territorial tax
Added to the federal rate: British Columbia 2% and 12%, Ontario 3.2% and 11.5%, Nova Scotia 1.5% and 14%. Alberta and Quebec administer their own corporate tax and are outside the federal table we read.Added to the federal rate.
GST/HST 5% to 15%
5% in Alberta, British Columbia, Manitoba, the territories, Quebec and Saskatchewan; 13% in Ontario; 14% in Nova Scotia since 1 April 2025; 15% in New Brunswick, Newfoundland and Labrador and Prince Edward Island.5% to 15% by province.
Part XIII withholding 25%
Non-residents pay 25% on amounts taxable under Part XIII - management fees, interest, dividends, rents and royalties among them. A treaty or the Income Tax Act can reduce or remove it.Reduced by treaty.
Tax summary
Federal corporate tax38% · 28% abated · 15% net general
Small business rate9% within the business limit
Business limit$500,000 · higher in NS, PEI and SK
Provincial corporate taxAdded to the federal rate
GST/HST5% to 15% by province
Part XIII withholding25% · reduced by treaty
*Figures as of 2026 per the Canada Revenue Agency. Treaty and regime positions are assessed per structure.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: Canadian entity, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a registered payment service provider.
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Canada · Bank of Canada
Launch your payment project in Canada with expert support.
Full-service assistance - from scoping the two regimes to the RPAA registration, FINTRAC, safeguarding and ongoing compliance.
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Written assessment within 2-5 business days
Request a free conclusion →FAQ
Canadian payment registration, answered.
Does Canada issue a payment licence?+
No. Canada runs two registration regimes: registration with the Bank of Canada under the Retail Payment Activities Act, and money services business registration with FINTRAC under the anti-money-laundering statute. Most payment businesses need both, and a business can fall inside one and outside the other.
What are the four RPAA tests?+
All four must be met: you perform one or more of the five payment functions, as a service or business activity that is not incidental to another service or business activity; you perform them in relation to electronic funds transfers; you have a place of business in Canada, or you direct retail payment activities at end users in Canada and perform them for those end users; and you fall outside the exclusions.
Who is excluded?+
Sections 6, 7 and 9 exclude banks, credit unions and certain provincially regulated institutions by entity, and merchant-issued closed-loop instruments, eligible financial contracts, securities transactions, ATM cash withdrawals, designated payment systems and internal transfers between affiliated entities by activity.
Is there a capital requirement?+
None. Neither the Retail Payment Activities Act nor the anti-money-laundering statute imposes a capital or net-worth requirement on a payment service provider, a money services business or a foreign money services business.
How must end-user funds be held?+
Section 20: in trust in a dedicated account, or in a prescribed account together with insurance or a guarantee equal to the amount held. No right of set-off or compensation may be asserted against the account, a ledger of each end user's balance is kept at the end of each day, and the Bank's guidance says deposit insurance alone is not sufficient.
What does registration cost?+
The RPAA registration fee is $2,500 for applications made in the first year, indexed to inflation by the formula in regulation 25(1). FINTRAC charges no registration fee. The annual assessment fee under the RPAA has not been set - the regulations establishing the methodology were pre-published, and the Bank will begin charging in due course.
How long does it take?+
The Bank notifies applicants of a complete application and of the decision as soon as feasible, with refusal notices inside 30 to 45 days depending on the circumstances, and the Minister sets the national security review periods. FINTRAC processes most complete applications within three months. Plan on four to eight months from first call.
Does a foreign provider have to register?+
Yes, where it directs retail payment activities at persons in Canada. There is no residency or local-office requirement under the Act. A foreign money services business must register with FINTRAC before it begins to operate and must designate a representative in Canada to receive notices.
How are payment companies taxed in Canada?+
The federal corporate rate is 38%, 28% after the abatement and 15% net general, with 9% for a Canadian-controlled private corporation inside the $500,000 business limit. Provincial tax is added. GST/HST runs from 5% to 15%, and Part XIII withholding on payments to non-residents is 25% unless a treaty reduces it.
Why Canada rather than the United States or the United Kingdom?+
Canada gives one federal registration with no capital and a $2,500 fee, where the United States needs money transmitter licences state by state with bonding, and the United Kingdom asks EUR 350,000 for an authorised e-money institution. The United States has the deeper market and the United Kingdom a three-month statutory clock and a mature safeguarding regime. Canada is the cheapest of the three to enter and the strictest about how you hold end-user funds.
A licence?+
No - two registrations instead.
The four tests?+
All must be met; see section 2 and the Bank's criteria.
Exclusions?+
Entity and activity, in ss. 6, 7 and 9.
Capital?+
None under either regime.
End-user funds?+
Trust account, or account plus insurance.
Cost?+
$2,500 indexed; FINTRAC free.
How long?+
4-8 months realistic.
Foreign providers?+
Register if you direct activity at Canada.
Taxes?+
15% federal net, 9% small; GST/HST 5-15%.
vs USA / UK?+
Cheapest entry; strictest on end-user funds.
Client notes
Google4.7★★★★★
Founders who wanted it done right.
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the Bank of Canada and FINTRAC or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.