Understanding RPAA Compliance and the Role of SOC 2

he Retail Payment Activities Act (RPAA), enforced by the Bank of Canada (BoC), establishes new compliance requirements for payment service providers (PSPs), fintechs, and money service businesses (MSBs) operating in Canada. With regulations focusing on operational risk, security, and incident response, PSPs must ensure they meet these standards to continue offering payment services.

For many businesses, SOC 2 compliance, an internationally recognized **security and risk management framework, already provides a strong foundation for meeting RPAA requirements.

While SOC 2 is not officially mandated by the BoC, PSPs that have undergone SOC 2 certification often find they already meet or exceed the expectations set by RPAA. The key is understanding how SOC 2 aligns with BoC’s requirements and how businesses can leverage their SOC 2 controls to streamline RPAA registration and compliance.

What is SOC 2, and Why Does It Matter for PSPs?

SOC 2 is an independent audit framework developed by the American Institute of Certified Public Accountants (AICPA). It evaluates how organizations secure, manage, and process sensitive data; a critical concern for payment providers handling financial transactions.

The framework is built on five Trust Service Criteria (TSC):

• Security – Protection against unauthorized access and cyber threats
• Availability – Ensuring systems remain operational and resilient
• Processing Integrity – Accuracy and reliability of transactions
• Confidentiality – Proper handling of sensitive financial data
• Privacy – Compliance with personal data protection standards

Bitpulse.ca provides SOC 2 assessments for PSPs, ensuring their systems meet industry-best security and operational standards. But how does this tie into BoC’s RPAA compliance framework?

How SOC 2 Aligns with RPAA Compliance Under the Bank of Canada

SOC 2 certification covers many of the same risk and security controls that the Bank of Canada requires under RPAA.

RPAA Requirement and how SOC 2 Covers It:

• Operational Risk Management: SOC 2 requires organizations to have internal controls, risk assessments, and monitoring in place, aligning with RPAA’s operational risk framework.
• Data Security & Cybersecurity: SOC 2’s Security and Confidentiality criteria ensure PSPs have strong access controls, encryption, and security policies to protect financial transactions.
• Incident Response & Business Continuity: SOC 2 mandates a structured incident response and disaster recovery plan, which meets RPAA’s requirements for handling cybersecurity events and disruptions.
• Data Governance & Privacy:SOC 2 includes strict policies on how organizations manage sensitive customer data, directly addressing RPAA’s data governance requirements.
• Third-Party Risk Management: PSPs relying on external vendors must conduct due diligence and risk assessments—a requirement under both SOC 2 and RPAA.

Turning SOC 2 Certification Into RPAA Compliance

While SOC 2 covers the key risk and security requirements outlined by the Bank of Canada, PSPs still need to officially register and maintain compliance under RPAA.

This is where AML Incubator plays a critical role. As a compliance solutions provider, AMLIncubator.com helps PSPs:

• Navigate the RPAA registration process with the BoC
• Map existing SOC 2 controls to RPAA requirements
• Ensure continuous compliance with regulatory expectations
• Avoid redundant compliance efforts by aligning SOC 2 audits with RPAA reporting

For PSPs that already hold SOC 2 certification, the path to RPAA registration with AML Incubator is far more straightforward. Rather than starting compliance efforts from scratch, businesses can use their SOC 2 framework as a foundation for RPAA compliance, significantly reducing costs and administrative burdens.

Future-Proofing PSP Compliance with SOC 2 and RPAA Alignment

The Bank of Canada’s RPAA framework marks a shift in how payment providers are regulated, but businesses already adhering to SOC 2 standards have a head start.

Rather than treating SOC 2 and RPAA as separate compliance efforts, PSPs should take advantage of their existing security framework to meet BoC’s expectations. With the right approach, SOC 2 compliance can serve as a direct pathway to RPAA registration—ensuring PSPs remain secure, compliant, and ready for the future of financial regulation.

Need Help with SOC 2 or RPAA Compliance?

If your business is already SOC 2 certified or looking to get ahead of RPAA compliance, Bitpulse.ca and AMLIncubator.com can help streamline the process and eliminate regulatory headaches.

➡️ Contact us today to learn how we can help your business stay compliant with ease.

Disclaimer

The views and opinions expressed in this article are for informational purposes only and do not constitute financial, legal, or compliance advice. AML Incubator and Bitpulse.ca recommend consulting a professional advisor for specific regulatory guidance.