Regulatory Change Ahead: Ensure your compliance with the Bank of Canada regulations Before September 7, 2025
Canadian regulatory frameworks for Money Services Businesses (MSBs) operating online are entering a period of significant transition. Starting November 1, 2024, all MSB’s that offer online money services (international transfers, remittances, exchange platforms, online accounts, e-wallets and more) must register with the Bank of Canada. Although we are currently in the second phase of the transition period, a thorough compliance with the regulations (RPAA and RPAR) is mandatory as of September 7, 2025.
If your company holds an MSB license but has not initiated the Bank of Canada registration process, the time to act is now.
The 60-Day Provision Is Ending
Currently, companies applying for registration with the Bank of Canada benefit from a streamlined entry point: after submitting their application, they are permitted to begin operations following a 60-day waiting period. This framework offers a degree of flexibility that has enabled many international MSBs to establish a Canadian presence while awaiting formal approval.
However, as of September 7, 2025, this process will change. Under the upcoming provisions of the Retail Payment Activities Act (RPAA), MSBs will be required to obtain full regulatory approval before commencing any business activity. No operations, no onboarding, and no transactions will be permitted until a registration decision is finalized.
If your company holds an MSB license but has not initiated the Bank of Canada registration process, the time to act is now.
The 60-Day Provision Is Ending
Currently, companies applying for registration with the Bank of Canada benefit from a streamlined entry point: after submitting their application, they are permitted to begin operations following a 60-day waiting period. This framework offers a degree of flexibility that has enabled many international MSBs to establish a Canadian presence while awaiting formal approval.
However, as of September 7, 2025, this process will change. Under the upcoming provisions of the Retail Payment Activities Act (RPAA), MSBs will be required to obtain full regulatory approval before commencing any business activity. No operations, no onboarding, and no transactions will be permitted until a registration decision is finalized.
A Lengthy and Uncertain Timeline
What makes this shift particularly consequential is the unknown nature of the approval timeline. Early indications suggest the process could take 6, 8, or even 12 months—a considerable delay for businesses seeking to enter or expand in the Canadian market.
Such delays carry significant implications:
Why MSB License Holders Must Act Now
Companies that initiate their registration before the September 7, 2025, deadline will still fall under the current framework and may begin operations after the standard 60-day waiting period. This creates a short but critical window for MSBs to secure their place in the Canadian market before more stringent approval timelines take effect.
If your firm has not yet started the registration process with the Bank of Canada, we strongly recommend beginning preparations immediately. This includes gathering the required documentation, reviewing your compliance infrastructure, and ensuring that your operational model aligns with the RPAA’s supervisory framework.
Supporting You Through the Transition
We specialize in helping companies navigate the complexities of launching and operating an MSB in Canada. With deep experience supporting both new market entrants and established international firms, we provide the insight and execution support needed to meet regulatory expectations with confidence and efficiency.
For more information, please visit:
https://www.bankofcanada.ca/core-functions/retail-payments-supervision/supervisory-framework-registration/
https://laws-lois.justice.gc.ca/eng/acts/R-7.36/page-1.html
What makes this shift particularly consequential is the unknown nature of the approval timeline. Early indications suggest the process could take 6, 8, or even 12 months—a considerable delay for businesses seeking to enter or expand in the Canadian market.
Such delays carry significant implications:
- Deferred revenue and operational rollout
- Missed opportunities for strategic partnerships
- Increased pressure from stakeholders and investors
- Competitive disadvantage relative to firms already registered
Why MSB License Holders Must Act Now
Companies that initiate their registration before the September 7, 2025, deadline will still fall under the current framework and may begin operations after the standard 60-day waiting period. This creates a short but critical window for MSBs to secure their place in the Canadian market before more stringent approval timelines take effect.
If your firm has not yet started the registration process with the Bank of Canada, we strongly recommend beginning preparations immediately. This includes gathering the required documentation, reviewing your compliance infrastructure, and ensuring that your operational model aligns with the RPAA’s supervisory framework.
Supporting You Through the Transition
We specialize in helping companies navigate the complexities of launching and operating an MSB in Canada. With deep experience supporting both new market entrants and established international firms, we provide the insight and execution support needed to meet regulatory expectations with confidence and efficiency.
For more information, please visit:
https://www.bankofcanada.ca/core-functions/retail-payments-supervision/supervisory-framework-registration/
https://laws-lois.justice.gc.ca/eng/acts/R-7.36/page-1.html
