PhotonPay Registers Under Canada's RPAA: Vetting Cross-Border PSPs

On this page 6 sections

1. What PhotonPay Announced on November 9
2. Canada's Retail Payment Activities Act in Plain English
3. What RPAA Registration Requires of a Payment Service Provider
4. How to Check a Provider on the Bank of Canada Registry
5. Red Flags When Choosing a Cross-Border Payments Provider
6. Vetting Checklist for U.S. Sellers Collecting or Paying Out in Canada

Key takeaways

• Bank of Canada registration belongs to one legal entity. Check the company named in your contract, not the brand on the website.
• A FINTRAC money services business registration covers anti-money-laundering. RPAA registration covers operational risk and the safety of the funds a provider holds.
• Under the RPAA, keeping funds at a bank with deposit insurance doesn't count as safeguarding. Ask in writing whether your balance is held in trust or in a segregated account backed by insurance or a guarantee.
• What you could lose if a provider fails is your peak balance with it, and your sweep schedule controls that number more than anything else.

PhotonPay said on Nov. 9, 2026, that its Canadian operating entity, Photon Dance CA Inc., is now registered with the Bank of Canada as a payment service provider under the Retail Payment Activities Act (RPAA). Canada RPAA registration means a payment service provider has cleared the Bank of Canada's entry requirements and is supervised on how it manages operational risk and protects the money it holds for users. If any provider collects Canadian dollars for you, holds a balance before paying you out, or funds your supplier payments, you can check its status yourself in about five minutes. You should.

What PhotonPay Announced on November 9

PhotonPay was founded in Hong Kong in 2015 and sells cross-border infrastructure to businesses: multi-asset wallets, local collection accounts, international payouts, foreign exchange, card issuing and embedded finance, in both fiat currency and stablecoins. According to the company's announcement, distributed through Newsfile and reported by Finextra, the new registration covers Photon Dance CA Inc., which was already registered with FINTRAC, Canada's anti-money-laundering agency, as a money services business.

The release also lists PhotonPay's U.S. footing: registration with FinCEN as a money services business and money transmitter licenses in multiple states. The company counts 35 payment licenses, authorizations and registrations across the Americas, Europe and Asia. The Paypers noted that other cross-border providers, including Skydo and Yolat, have also registered under the RPAA.

Two details matter more to a merchant than the license count. The registration belongs to one legal entity, and the FINTRAC registration that entity already held covers different risks.

Canada's Retail Payment Activities Act in Plain English

The Retail Payment Activities Act is Canadian federal law, passed in 2021. It isn't a Visa or Mastercard network rule, and it isn't any processor's pricing policy. It gives the Bank of Canada the job of supervising payment service providers (PSPs) that perform retail payment activities, such as holding funds for a user until the user withdraws them or sends them to someone else.

Canada now runs two regimes side by side. FINTRAC handles anti-money-laundering. The Bank of Canada handles operational resilience and the safety of client money. A provider can be registered with one and not the other, which is why a FINTRAC number by itself tells you nothing about how your balance is protected.

The rollout took time:

The registry filled in slowly because the Department of Finance runs a national security review on every applicant before the Bank can register it. Providers starting new activity in Canada must apply at least 60 days before they begin.

The Act also reaches past consumer wallets. One independent review of the registry data lists acquirers, processors, payment gateways, payroll providers, buy now, pay later infrastructure and marketplaces that control the revenue account among the businesses covered. Foreign providers can register too, and the regulations let them hold user funds at eligible Canadian or foreign financial institutions.

What RPAA Registration Requires of a Payment Service Provider

Registered providers must keep a risk management framework that they review, test and update, plus incident response procedures, reporting and recordkeeping. Fund safeguarding bears most directly on your money.

Under section 20 of the Act, a provider that holds user funds until they're withdrawn or transferred has to protect them in one of two ways. It can hold them in trust, in a trust account used for nothing else. Or it can keep them in a segregated account used for nothing else and back that account with insurance or a guarantee from an eligible financial institution. The Retail Payment Activities Regulations add a written safeguarding framework, a named senior officer responsible for it, and an independent review of that framework every three years. The stated goal is that users get reliable access to their funds without delay, including if the provider becomes insolvent.

Deposit Insurance Alone Doesn't Qualify

This is the detail to hold a provider to. As McMillan LLP's analysis of the Bank of Canada guidance explains, simply keeping user funds at a bank covered by a federal or provincial deposit insurance program does not meet the safeguarding requirement. A provider that tells you your money is "at an insured bank" has answered a different question from the one you asked.

Registration is also not a seal of approval. The Bank of Canada describes registered providers as having met the legal requirements to register, such as being in scope of the Act and paying the required fees, and having cleared the national security screening. Whether they comply day to day is what supervision tests afterward.

Illustrative Example: How Much of Your Money Sits With the Provider

These numbers are illustrative. Assume a U.S. wholesaler sells CAD 60,000 a month to Canadian buyers, who pay into a provider's local CAD collection account. Sales arrive evenly at about CAD 2,000 a day. The seller keeps a CAD 10,000 float in the same account to pay a Canadian 3PL, and sweeps everything else to its U.S. bank on a fixed schedule.

Moving from a two-week sweep to a weekly one cuts the peak balance by more than a third. More frequent conversions can cost more in FX spreads or per-transfer fees, so check your provider's fee schedule before you change anything. The decision rule is simple: the bigger your peak balance, the more the provider's safeguarding answer matters, and the more you should want it in writing.

How to Check a Provider on the Bank of Canada Registry

To verify payment provider registration, work from your contract rather than the provider's website.

1. Find the contracting entity. Open your provider agreement and look for the legal name of the company you contracted with. Brands often operate through several entities, and only the one named on the registry is registered. PhotonPay's registration, for example, is in the name of Photon Dance CA Inc.
2. Search the registry. The Bank of Canada's registry of payment service providers is free and searchable, and it's updated on a rolling basis.
3. Read the whole record. The status should say Registered, not under review. Check the violations field. Then look at which payment functions the provider declared: if it holds your balance but didn't declare holding funds, ask why.
4. Check the other two lists. The Bank also publishes a list of applicants and a list of refused or revoked registrations.
5. Save the evidence. Screenshot the record with the date and file it with the contract.

A missing name doesn't automatically mean wrongdoing. Some providers fall outside the Act, and the applicants list excludes companies still working with the Bank to settle whether they're in scope. Ask the provider, in writing.

Red Flags When Choosing a Cross-Border Payments Provider

• Registration is claimed for "the group," but your contract names an entity in another country that doesn't appear on the registry.
• The provider offers a FINTRAC money services business number as proof your funds are safe. That registration covers anti-money-laundering obligations.
• Asked where your balance sits, the provider says "a major bank" or "insured" and can't name a trust account, an insurance policy or a guarantee.
• Its registry status reads under review, yet the sales team calls it registered.
• The name appears on the refused or revoked list.
• Someone offers to onboard you under another merchant's account or suggests describing your products differently to pass review. That is transaction laundering, and the risks fall on the merchant as well as the provider. Walk away.
• The agreement says nothing about how you'll be told of outages or security incidents.

Vetting Checklist for U.S. Sellers Collecting or Paying Out in Canada

How you sell decides where your money rests. A B2B wholesaler invoicing Canadian buyers on net-30 terms sees large, lumpy payments land in a CAD collection account. A dropshipper prefunds a wallet to pay suppliers, so the balance is highest right before a big order run. A marketplace seller waits on scheduled payouts. A U.S. marketplace paying out to Canadian vendors may be performing payment functions itself and should get Canadian counsel to assess its own position. For everyone:

• Map every point where your money rests: collection accounts, wallets, payout balances and reserves.
• Run the registry check on each entity that holds your funds, not just the brand.
• Request a safeguarding letter that names the method (trust, or segregated account plus insurance or guarantee), the financial institution and the date of the last independent review.
• Set a sweep schedule that keeps your peak balance at a level you could afford to have frozen for a while.
• Confirm the U.S. side too: the provider's U.S. registrations and licenses, and your own OFAC sanctions screening for cross-border customers.
• Re-check the registry each quarter and whenever the provider moves your account to a different entity.

Card payments from Canadian buyers are a separate track. A U.S. merchant account settles card sales to your bank account, and multi-currency merchant accounts that settle in foreign currency can let you price and settle in CAD without leaving money parked in a third-party wallet. MannyPay's international payment processing team reviews multi-currency acceptance, cross-border acquiring paths and whether USD or local-currency settlement fits your business.

This article is general information, not legal advice. Confirm how the RPAA applies to your setup with a qualified Canadian lawyer.

This week, pull every agreement with a provider that touches Canadian dollars, find the legal entity named in each, and search it on the registry. If the answers leave you wanting your card volume to settle straight to your own bank, request a free quote and a MannyPay specialist will respond within one business day.

Sources

1. PhotonPay Strengthens North American Regulatory Footprint with Canada's RPAA Registration (Newsfile via Yahoo Finance, Nov. 9, 2026)
2. PhotonPay becomes registered PSP in Canada (Finextra)
3. PhotonPay registers with Bank of Canada as payment service provider (The Paypers)
4. PhotonPay Announces Canadian Payment Service Provider Registration (Crypto Breaking)
5. PhotonPay Strengthens North American Regulatory Footprint With Canada's RPAA Registration (EQS Newswire via MENAFN)
6. Registry of payment service providers (Bank of Canada)
7. Retail payments: supervisory framework and lists (Bank of Canada)
8. Bank of Canada Opens Registration Period for Payment Service Providers (Nov. 1, 2024)
9. Bank of Canada publishes applicants' list of retail payment service providers (Dec. 2, 2024)
10. Update on Retail Payments Supervision and PSP Registry (NCFA Canada)
11. Bank of Canada's PSP Registry Goes Live Under RPAA (NCFA Canada)
12. Bank of Canada RPAA Payment Service Providers Registration Update: What Happens on September 8, 2025? (Stikeman Elliott)
13. Retail Payment Activities Act, S.C. 2021, c. 23, s. 177 (Justice Laws Website)
14. Retail Payment Activities Regulations, SOR/2023-229 (CanLII)
15. Canada Gazette, Part II: Retail Payment Activities Regulations, SOR/2023-229
16. Safeguarding End-User Funds under the Retail Payment Activities Act (McMillan LLP)
17. The Wait Is Over: Final Regulations to the Retail Payment Activities Act (Blakes)
18. RPAA: Bank of Canada Supervision of Payment Service Providers (private.law wiki)

AR

About the author

Adrian Reyes

Adrian Reyes is Senior Payments & Fintech Editor for Beyond the Swipe, covering credit card processing, merchant accounts, payment technology and processing fees.

This article is for general educational purposes and is not legal, tax or financial advice. Card network rules and state laws change; confirm current requirements for your business.