Canada. End-user funds under the RPAA.

    Payment service providers performing retail payment activities for end users in Canada are registered with and supervised by the Bank of Canada under the Retail Payment Activities Act.

    Rules applied
    Safeguarding of end-user funds, RPAA s.20 and Regulations ss.13 to 17.
    Reports prepared
    RPAA annual report, safeguarding section 2 and end-user funds in section 4.
    Checked
    Every business day, for each entity, in Canadian dollars.

    What the Bank of Canada expects.

    End-user funds held in trust, or in a dedicated account fully backed by insurance or a guarantee, from the next business day after receipt.

    Safeguarding of end-user funds

    Registered payment service providers that hold end-user funds. Supervised by Bank of Canada.

    Retail Payment Activities Act s.20; Retail Payment Activities Regulations SOR/2023-229 ss.13-17, in force 8 September 2025
    RequirementWhat the rule saysReference
    HowIn trust, in a trust account used for no other purpose, or in a dedicated account backed by insurance or a guarantee at least equal to the funds in it.RPAA s.20(1)(a), (c)
    By whenOn receipt, and no later than the next business day.RPAA s.20(1); Regs ss.13-16
    Insurance or guaranteeFrom an unaffiliated provider, paid outside the PSP's estate, with 30 days' notice of cancellation.Regs s.14
    Account providerAcknowledges in writing that it has no claim on the funds for anything owed to it.RPAA s.20; Regs s.13
    Records and reviewsDaily records, investigation of every shortfall, an annual framework review and an independent review every three years.Regs ss.15-17

    How Safeheld applies it. A dedicated account counts up to the lower of its balance and its qualifying cover. Deposit insurance does not count.

    Returns and reports.

    What is filed, when and where, and exactly what Safeheld produces for it.

    RPAA annual reportBank of Canada
    How often
    Annual, for the calendar year
    Due
    31 March
    Filed through
    PSP Connect, completed online
    Completion workbook

    A workbook in the form's order: Section 2 safeguarding questions, including the log of every shortfall, and Section 4 end-user fund amounts, filled from the records. Every other question is listed for your team.

    PSP Connect accepts no file. Your team keys the answers in, and the Bank may change the form each year. Every report is reviewed and approved by your team before it is filed.

    Every day

    What Safeheld runs for Canada.

    Reconcile. Trust and dedicated accounts matched to the end-user ledger every business day, in Canadian dollars.
    Investigate. Every shortfall investigated and logged with its date, cause, largest daily amount and fix, as the annual report asks.
    Forecast. Funding needs for the next 24 hours, 7 and 30 days.
    Act. Top-ups proposed and approved within limits, recorded against the position once paid.
    Report. The annual report workbook, and the records behind the framework review and the independent review.
    Nexus Payments CanadaCAD, 30 Sep 2026, close of businessMeets
    Owed to customersC$6,402,118.00
    Counted under the rulesC$6,455,900.00
    ExcessC$53,782.00
    Accounts
    Trust accountRPAA s.20(1)(a)Meets
    Dedicated account with insuranceRPAA s.20(1)(c)Meets
    A dedicated account counts up to the lower of its balance and its cover.

    Questions.

    Which method should we use?

    Both are allowed: a trust account, or a dedicated account backed by insurance or a guarantee at least equal to the funds. Safeheld tests whichever you use, and counts a dedicated account only up to its cover.

    What counts as a shortfall?

    Any day the funds safeguarded are less than the end-user funds held. Each one is investigated and logged with its date, cause, largest daily amount and fix, which the annual report asks for.

    Does CDIC deposit insurance count?

    No. Only insurance or a guarantee meeting the Regulations, from an unaffiliated provider, counts.

    Can Safeheld submit the annual report?

    No. PSP Connect is completed online and accepts no file. Safeheld produces the answers in the form's order for your team to enter.

    Customer money in Canada, accounted for every day.