BoC Annual Report: You missed the deadline, now what?
The March 31, 2026 deadline for the first-ever annual report under the Retail Payment Activities Act (RPAA) has now passed. For PSPs that submitted on time, this chapter is closed for another year. For those who have not yet filed, there are important steps to take now.
Who Was Required to File
Any PSP that received final registration before March 9, 2026 was required to submit an annual report to the Bank of Canada covering the 2025 calendar year, with a deadline of March 31, 2026. PSPs registered between March 9 and March 30, 2026 were granted an extension to April 28, 2026. Businesses that were still pending approval as of March 31 were exempt from the 2025 filing cycle.
A common misconception is that an inactive year means there is nothing to report. That is not the case. PSPs are required to file regardless of activity level. If your business was registered but not yet operational during the 2025 reporting year, a $0 or nil report was still required.
Who Was Required to File
Any PSP that received final registration before March 9, 2026 was required to submit an annual report to the Bank of Canada covering the 2025 calendar year, with a deadline of March 31, 2026. PSPs registered between March 9 and March 30, 2026 were granted an extension to April 28, 2026. Businesses that were still pending approval as of March 31 were exempt from the 2025 filing cycle.
A common misconception is that an inactive year means there is nothing to report. That is not the case. PSPs are required to file regardless of activity level. If your business was registered but not yet operational during the 2025 reporting year, a $0 or nil report was still required.
- To verify whether your business has been approved as a PSP and whether you are required to submit an annual report, you can check the Bank of Canada’s registry of approved companies.
What the Report Covers
The annual report is more involved than many registrants anticipated. Depending on the scope of a PSP's retail payment activities, the form contains between 50 and 95 questions. The report asks PSPs to account for the following:
The Cost of Non-Filing
Missing this deadline carries real consequences. The Bank of Canada has a range of enforcement tools at its disposal, including administrative monetary penalties of up to $10 million and the potential revocation of a PSP's registration. Non-filing is a clear, documentable violation that the regulator is well-positioned to act on.
That said, filing late is meaningfully better than not filing at all. Demonstrating a commitment to meeting regulatory obligations, even after a deadline has passed, is taken into account. Continued inaction only increases exposure.
How Approved MSB Can Help
Our team processed dozens of annual reports on behalf of clients this cycle. That experience has given us a thorough working knowledge of the filing process, including common points of confusion around transaction categorization, risk framework documentation, safeguarding disclosures, and navigating the PSP Connect portal.
If you missed the deadline, are unsure whether you were required to file, or would like experienced support managing the submission, we encourage you to reach out. The sooner you act, the better your position.
The annual report is more involved than many registrants anticipated. Depending on the scope of a PSP's retail payment activities, the form contains between 50 and 95 questions. The report asks PSPs to account for the following:
- Operational risk and incident response frameworks, including cybersecurity, fraud, and third-party risk management
- Safeguarding of end-user funds, including whether a trust account or an insurance and guarantee model is being used
- Transaction data, including the number and value of electronic funds transfers broken down by currency, total number of end users, and the amount of funds held on their behalf
- Any significant changes during the reporting year, such as new outsourcing arrangements, geographic expansions, or technology changes that could materially affect operational risk
- Core financial metrics, including total revenue, operating expenses, and total equity
The Cost of Non-Filing
Missing this deadline carries real consequences. The Bank of Canada has a range of enforcement tools at its disposal, including administrative monetary penalties of up to $10 million and the potential revocation of a PSP's registration. Non-filing is a clear, documentable violation that the regulator is well-positioned to act on.
That said, filing late is meaningfully better than not filing at all. Demonstrating a commitment to meeting regulatory obligations, even after a deadline has passed, is taken into account. Continued inaction only increases exposure.
How Approved MSB Can Help
Our team processed dozens of annual reports on behalf of clients this cycle. That experience has given us a thorough working knowledge of the filing process, including common points of confusion around transaction categorization, risk framework documentation, safeguarding disclosures, and navigating the PSP Connect portal.
If you missed the deadline, are unsure whether you were required to file, or would like experienced support managing the submission, we encourage you to reach out. The sooner you act, the better your position.
