A. Governance and Compliance

RPAA expects active governance that is documented, reviewed, and enforced. This means your organization must have policies and procedures that keep governance real, not theoretical.

• Compliance Policy: Defines your compliance framework, assigns Chief Risk Officer or equivalent responsibilities, and sets reporting lines to senior management and the board.

• Internal Audit or Compliance Review Policy: Establishes the cadence and scope of internal reviews, ensuring they are aligned with RPAA supervisory themes.

• Governance and Oversight Policy: Assigns the board and senior management direct responsibility for oversight of compliance, risk management, and safeguarding of funds.

To stay compliant, these policies must not only be drafted but also be re-approved regularly, supported with evidence such as board minutes, and operationalized through procedures that staff actually follow.

B. Risk Management and Operational Resilience

The RPAA requires that PSPs anticipate and withstand operational risks. This means you must be able to identify, assess, mitigate, and monitor threats that can disrupt payments.

• Risk Management Policy: A clear risk taxonomy, heat maps, treatment plans, and monitoring approach are required.

• Information Security and Cybersecurity Policy: RPAA oversight will test whether access controls, vulnerability patching, and system monitoring are in place and evidenced.

• Business Continuity and Disaster Recovery Policy: Recovery time objectives (RTOs) and recovery point objectives (RPOs), scenario testing, and communications playbooks must be documented and tested.

• Third-Party and Vendor Risk Policy: Every outsourcing relationship must be governed with due diligence, contractual protections, and ongoing monitoring.

• Incident Response and Reporting Policy: You must have clear procedures for detecting, triaging, escalating, and reporting material incidents, both to the regulator and to end-users.

Supervisory reviews will not accept policy statements alone. They expect to see a Risk Management and Incident Response Framework (RMIRF), incident playbooks, registers of risks and incidents, and documented testing protocols that demonstrate your organization is truly ready.

C. Fund Safeguarding and Financial Protection

Perhaps the most visible risk under RPAA is the safeguarding of end-user funds. A PSP must prove that funds are segregated, reconciled, and protected through robust structures.

• Funds Safeguarding Policy: Must set out whether you use a trust account, insurance, or guarantee structure, and how roles are assigned.

• Segregation of Funds Policy: Requires daily reconciliation, exception handling procedures, and a clear audit trail.

• Liquidity and Settlement Policy: Demands that you demonstrate liquidity planning, timely settlement practices, and internal financial controls.

The Bank of Canada can request reconciliation records, trust or insurance documents, and your safeguarding framework at any time. If these are not up-to-date and accurate, you risk regulatory intervention.

D. Transparency and User Protection

User protection is a cornerstone of RPAA. PSPs must ensure clarity, fairness, and timely communication in all customer interactions.

• End-User Disclosure Policy: Terms, fees, and rights must be standardized and written in plain language.

• Complaints Handling Policy: Requires a documented process for intake, escalation, resolution, and regulator reporting of complaints.

• Incident Notification Policy: PSPs must notify users of outages, breaches, or other material incidents within defined timelines.

Supervisors will expect disclosure templates, complaint logs, and user-facing notification processes to be in place and proven effective.

Why a Chief Risk Officer Is Central

All of these obligations roll up to one central expectation: a senior officer must be accountable for risk management and incident response. In practice, this means appointing a Chief Risk Officer (CRO) or equivalent who can:

• Maintain and update all RPAA policies.

• Conduct quarterly risk reviews and board-level reporting.

• Oversee safeguarding structures and reconciliation checks.

• Supervise user protection processes and validate incident communications.

Without a CRO, these responsibilities end up fragmented across the organization, creating gaps that regulators will quickly identify.

A Typical Year Under RPAA

Remaining compliant requires a steady cadence of work:

• Quarter 1: Refresh gaps against new guidance; update RMIRF; deliver a board briefing; complete vendor due diligence.

• Quarter 2: Test cybersecurity and disaster recovery plans; review complaint and incident metrics; reconcile evidence sampling.

• Quarter 3: Conduct operational and fraud risk reviews; run incident simulations; update policies for board approval.

• Quarter 4: Prepare the annual attestation package; compile evidence; deliver staff training refreshers; plan for the next year.

This cycle is how RPAA expects PSPs to demonstrate operational maturity.

Implementation Roadmap

To meet these expectations, PSPs must build an implementation path:

1. Gap analysis: Map existing policies and controls against RPAA obligations and identify critical gaps.

2. Governance and risk drafting: Produce and approve governance and risk management policies; establish an RMIRF.

3. Safeguarding and transparency: Formalize fund protection and user protection policies; standardize disclosure templates.

4. Integration and adoption: Secure board approvals, deliver staff training, and embed compliance cycles into operations.

Who Needs to Worry the Most

• Fast-growing PSPs without dedicated compliance infrastructure risk being blindsided by supervisory reviews.

• International entrants face duplication of effort if they fail to adapt global policies to Canadian RPAA requirements.

• Complex vendor ecosystems introduce added risks where third-party dependencies create compliance vulnerabilities.

The Bottom Line

Remaining compliant under RPAA is not a matter of drafting a few policies; it is about creating an operating rhythm that includes a Chief Risk Officer, regular board engagement, tested resilience, safeguarding controls, and user-facing transparency. For most PSPs, this means a heavy lift in terms of human resources, processes, and evidence.