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New Brunswick has no province-level payment-services licensing regime; PSPs operating in or serving NB are captured by the federal Retail Payment Activities Act (RPAA), administered by the Bank of Canada. RPAA registration has been mandatory since November 2024, and as of 8 September 2025 registered PSPs must have established risk-management and funds-safeguarding frameworks and must submit annual reports.
Outlook
The Bank of Canada is expected to continue publishing and updating its registry of registered PSPs as the post-transition supervisory phase proceeds. New Brunswick's dual federal-provincial licensing structure -- RPAA registration for nonbank PSPs alongside FCNB oversight of provincially chartered credit unions -- remains the operative market-entry framework.
Licensing, Authorisation & Market Access
New Brunswick's payment service provider population is governed entirely by the federal Retail Payment Activities Act regime, with no province-specific licensing or authorisation layer identified. Individuals and entities subject to the RPAA are required to register with the Bank of Canada; the initial registration window for existing PSPs ran from 1 to 15 November 2024, and any new or late-entrant PSP must register before performing any retail payment activity in the province. As of 8 September 2025, core operational-risk, incident-response and end-user-funds-safeguarding provisions became operative, requiring registered PSPs to maintain established risk-management frameworks and to segregate end-user funds under the Act's safeguarding mechanism. Supporting this registration architecture, the Bank of Canada's PSP Connect web portal is live, and a public registry of registered PSPs launched in October 2025, updated on a rolling basis, listing PSPs that have cleared national-security screening as part of the registration process. This gives market participants and counterparties visibility into which entities are properly registered.
A further compliance marker for the registered PSP population is the annual reporting cycle: PSPs that performed retail payment activity in 2026 must submit their 2026 annual report to the Bank of Canada by 31 March 2027. The status of the assessment-fee regulations under sections 99 to 100 of the associated regulations remains uncommenced as of the most recent reporting available, a point that should be read with some caution given the comparatively thin sourcing behind that specific detail relative to the core registration and safeguarding findings, which rest on primary Bank of Canada material. Overall, the bank-versus-non-bank distinction in this jurisdiction is subsumed within the RPAA's uniform application: the Act's registration, safeguarding and reporting requirements apply to non-bank payment service providers and e-money-type entities operating in New Brunswick without a separate provincial layer of authorisation.
Outlook
The 31 March 2027 annual-report filing deadline is the next concrete marker for this module, and will offer the first indication of the scale and composition of the RPAA-registered PSP population actually operating in or from New Brunswick. Whether the currently uncommenced assessment-fee regulations move toward commencement is a separate item to track, since their activation would introduce a new direct cost for registered PSPs; nothing in the record reviewed indicates a commencement date at this time.
3 earlier distinct update(s)
Licensing, Authorisation & Market Access
New Brunswick has no province-level payment-services licensing regime; the province's entire payments regulatory exposure runs through the federal Retail Payment Activities Act (RPAA), administered by the Bank of Canada. Registration under the RPAA has been mandatory since November 2024 for any payment service provider operating in or serving New Brunswick, and there is no distinct provincial licence, exemption, or supplementary authorisation layer for such firms. This places New Brunswick's PSP market-access framework entirely within the federal architecture, with the bank-versus-non-bank distinction resolved at that federal level: the RPAA captures non-bank payment institutions and e-money issuers rather than deposit-taking banks, which remain under the existing federal prudential banking framework.
A significant compliance milestone within this regime took effect on 8 September 2025: registered PSPs must now have established risk-management and funds-safeguarding frameworks and must submit an annual report to the Bank of Canada. This represents a substantive operational obligation layered on top of the initial 2024 registration requirement, moving the regime from a registration-only gate to one carrying ongoing prudential-style expectations for non-bank PSPs. The Bank of Canada's public PSP registry is live and updated on a rolling basis, giving counterparties, merchants, and consumers a means of confirming a given PSP's registration status, and the Bank of Canada has stated that these registered PSPs are subject to risk supervision and enforcement activities, with unregistered PSPs facing enforcement action for operating outside the regime.
For market-access purposes, the practical implication is that any PSP seeking to serve New Brunswick customers must complete federal RPAA registration; there is no province-specific shortcut or additional barrier beyond that federal gate. This uniformity means New Brunswick's market-access posture for payment institutions and e-money issuers mirrors that of every other Canadian province, with the safeguarding and reporting obligations introduced in September 2025 representing the most recent substantive tightening of that federal gate.
Outlook
The RPAA registration and safeguarding regime is now fully in its operative phase, with the September 2025 risk-management and annual-reporting requirements bedded in and the public registry functioning as an ongoing enforcement-visibility mechanism. No New Brunswick-specific development is expected to alter this picture; any further tightening or loosening of PSP market-access conditions affecting the province would originate from further federal Bank of Canada rulemaking rather than any provincial action.
Licensing, Authorisation & Market Access
The Consumer-Driven Banking Act received Royal Assent on 2026-03-26 as Division 9, Part 5 of Bill C-15, establishing a federal accreditation framework for open-banking participants overseen by the Bank of Canada. The framework applies uniformly across Canada, including New Brunswick, which has no subnational payments-licensing regime of its own; obliged entities in the province face exactly the same accreditation timeline and criteria as those operating elsewhere in the country. The framework's accreditation model is structured to cover both bank and non-bank participants, meaning market access for non-bank payment institutions and e-money institutions runs through the identical federal gateway as it does for banks and payment-service providers, rather than through a separate lighter-touch or heavier-touch track. Proposed Consumer-Driven Banking Regulations, published in Canada Gazette Part I on 2026-06-27, would operationalize this accreditation framework: applicants would submit prescribed information and pay a C$2,500 application fee, and the sixty-day comment period on these proposed regulations closes 2026-08-26.
Outlook
The regulations' comment period closing on 2026-08-26 is the concrete near-term marker for this module; the shape of the final accreditation criteria, security standards and breach-reporting obligations that emerge from that process will determine the practical market-access bar for both bank and non-bank participants seeking to operate under the Consumer-Driven Banking framework, including those based in New Brunswick.
Licensing, Authorisation & Market Access
Canada's Retail Payment Activities Act moved from a registration-stage regime to a fully operational supervisory regime this cycle. Registration for payment service providers via the Bank of Canada's PSP Connect portal opened November 1, 2024, carrying a CAD 2,500 application fee. The next operational milestone landed this cycle: the Bank of Canada's own frequently-asked-questions guidance confirms that the first annual PSP report, covering 2025 calendar-year activity, is due no later than March 31, 2026, with the reporting form made available in PSP Connect early in the year. This shifts the RPAA regime from a one-time registration event to a recurring annual compliance obligation for every registered nonbank payment service provider.
Backing that reporting obligation is a materially expanded enforcement toolkit. The Bank of Canada's supervisory powers under the RPAA now range from warning letters through administrative monetary penalties of up to CAD 10 million, up to and including outright registration revocation. This is a substantial escalation from a registration-only regime, and it applies specifically to the nonbank payment-institution and electronic-money-institution population that the RPAA brings under federal supervision; deposit-taking banks remain under Canada's separate prudential banking framework rather than this registration and reporting regime, a distinction that matters for assessing counterparty risk anywhere in a payment chain touching New Brunswick. The underlying statute itself carries a currency date of June 14, 2026, reflecting amendments made March 26, 2026, indicating the legislative text itself has been actively maintained rather than static since initial enactment.
Taken together, the annual reporting deadline and the newly explicit enforcement ceiling mean that nonbank PSPs registered to serve New Brunswick and other Canadian markets are now operating inside a live, recurring supervisory cycle with real financial and existential consequences for non-compliance, a materially different risk posture than the registration-only phase that preceded it.
Outlook
The next concrete test of this regime is enforcement in practice: whether the Bank of Canada issues its first RPAA administrative monetary penalty or revocation action following the March 2026 reporting deadline will indicate how actively the newly operational enforcement ceiling is being used rather than held in reserve.
Sources and findings (7)
- T1https://laws-lois.justice.gc.ca/eng/acts/R-7.36/page-1.htmlretrieved
- T1https://www.bankofcanada.ca/core-functions/retail-payments-supervision/about-retail-payments-supervision-mandate/retrieved
- T3https://gowlingwlg.com/en/topics/fsxt/retail-payment-activities-actretrieved
- T1https://fintrac-canafe.canada.ca/msb-esm/msb-engretrieved
- T1https://fcnb.ca/en/personal-finances/credit-unionsretrieved
- T1https://www2.gnb.ca/content/gnb/en/services/services_renderer.695.Credit_Union_Incorporation.htmlretrieved
- T3https://advapay.eu/emoney-and-payment-institution-licensing/money-services-business-registration-in-canada-msb-fmsb/retrieved