What Is a Risk Management and Incident Response (RMIR) Framework Under RPAA?

Learn how the RPAA’s Risk Management and Incident Response framework helps PSPs protect confidentiality, availability, and integrity.

A Risk Management and Incident Response (RMIR) framework is one of the cornerstones of the Retail Payment Activities Act (RPAA) and the supporting Retail Payment Activities Regulations (RPAR). It is how payment service providers (PSPs) in Canada make sure their systems, processes, and people can withstand risks and respond effectively when incidents happen. The Bank of Canada supervises compliance with these requirements and has published detailed expectations on operational risk and incident response (Operational Risk and Incident Response Guideline).

The RMIR framework ensures the confidentiality, integrity, and availability of retail payment activities. In practical terms, that means keeping payment data safe from leaks, preventing corruption or manipulation of transactions, and making sure services stay up and running when Canadians need them.

Objectives and Required Elements

Under section 24 of the RPAA and Part 3 of the RPAR (Regulations link), every PSP must establish, implement, and maintain an RMIR framework. The objectives are threefold:

Preserve confidentiality of data and payment information
Ensure availability of retail payment activities even during disruptions
Maintain integrity of transactions and supporting systems

The Bank of Canada expects PSPs to take a proportional approach. A large global payments firm may need complex, layered systems, while a small money services business (MSB) may meet requirements with streamlined controls. What matters is that each provider identifies its operational risks, puts protections in place, detects and classifies incidents, and responds quickly when issues arise.

Classifying Assets, Risks, and Responsibilities

Building an RMIR framework begins with mapping out all assets and processes that support retail payment activities. That includes payment platforms, customer databases, staff roles, and even third-party vendors. Each asset must be reviewed for its criticality to payment operations, much like a business impact analysis under the RPAA continuity rules (Business Continuity and Disaster Recovery Guidance).

Once assets and processes are mapped, the next step is identifying risks. The RPAR requires PSPs to consider risks from failed systems, human error, third-party dependencies, new technologies, and external events like cyberattacks or power outages. PSPs must also classify the severity of incidents. For example, a minor system glitch may be logged internally, but a material incident anything that significantly affects availability, confidentiality, or end-user funds must be reported to the Bank of Canada within strict timelines (Incident Notification Guideline).

Assigning responsibilities is equally important. The framework must clearly define roles for the board of directors, senior officers, risk officers, compliance officers, and incident managers. Each role should have a backup to ensure continuity if the primary person is unavailable. This governance ensures accountability while respecting separation of duties.

Reviews, Testing, and Independent Assessments

A framework that is never tested is only a plan on paper. The RPAA requires PSPs to review and test their RMIR frameworks regularly. This includes tabletop exercises, live simulations, and stress testing of systems to confirm that recovery objectives are realistic.

According to the RPAR and Bank of Canada supervisory guidance, PSPs must:

Conduct internal reviews and testing at least annually
Update frameworks after significant changes or new activities (Significant Change Notices Guide)
Undergo an independent review at least once every three years, performed by a qualified person who is not involved in maintaining the framework

These independent reviews provide assurance that PSPs are not marking their own homework. They also give the Bank of Canada evidence that controls are working as intended and that weaknesses are being addressed.

Why the RMIR Framework Matters

The RMIR framework is more than a regulatory obligation. It is how PSPs maintain trust with their customers and partners. Canadians expect payment services to be reliable, secure, and available on demand. By protecting confidentiality, ensuring availability, and maintaining integrity, the RMIR framework strengthens confidence in the financial system as a whole.

For PSPs, it reduces financial, legal, and reputational risks. For customers, it means their payments and funds are secure. For the wider ecosystem, it prevents disruptions from spreading across networks and affecting other providers.

The Bank of Canada has made clear in its at-a-glance guidance (link) that operational risk management is not optional. It is a core requirement under the RPAA, on par with safeguarding end-user funds and annual reporting.

Conclusion

The RPAA requires PSPs to take operational risk and incident response seriously. By classifying assets, identifying risks, assigning responsibilities, and testing frameworks regularly, providers not only stay compliant but also strengthen their resilience. Independent reviews every three years keep the framework objective and credible.

If you are building or updating your RMIR framework, you do not need to do it alone. Visit Comply North’s pricing page to see how affordable compliance support can be, or contact our team to speak with experts who can help you align with the RPAA and Bank of Canada guidelines.