FINTRAC’s New Mandatory Registration Requirement: What Every Reporting Entity Needs to Do

Most businesses covered by Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) have never had to enroll with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). Bill C-12, the Strengthening Canada’s Immigration System and Borders Act, changes that. It received Royal Assent on March 26, 2026, and creates a FINTRAC mandatory registration regime, called enrolment, with periodic renewal and a risk of revocation.

Timing matters. The enrolment provisions take effect in line with regulations that have not yet been published, so this is a preparation window rather than a filing deadline. This article explains who is affected, how the regime works, and what reporting entities can do now.

Key Highlights

• Bill C-12 requires businesses subject to the PCMLTFA to enroll with FINTRAC, other than those already required to register, such as money services businesses (MSBs).
• Enrolment is not a one-time step. Entities must renew periodically and notify FINTRAC of changes to their information within 30 days.
• FINTRAC can revoke enrolment, including where an entity fails to respond to an information request within 30 days.
• Failing to enroll is an offence under section 74 of the amended PCMLTFA.
• The enrolment provisions come into force in line with regulations to be published in the Canada Gazette, Part II.
• Higher penalties and mandatory compliance agreements already apply to violations after March 26, 2026.

What Is FINTRAC’s Mandatory Registration Requirement?

Today, only domestic and foreign MSBs must register with FINTRAC before they operate. Every other reporting entity carries PCMLTFA obligations without any formal enrolment process. FINTRAC currently describes registration for MSBs as a distinct requirement for that sector.

Bill C-12 adds sections 11.4001 to 11.4015 to the PCMLTFA. Under these provisions, every person or entity covered by section 5 of the Act must enroll, with limited exceptions. Section 5 reaches a wide range of sectors, including financial entities, securities dealers, casinos, real estate brokers, and accountants. The exceptions include people acting solely as employees or agents of another reporting entity. MSBs that already register are not required to enroll a second time.

Enrolment requires a formal application, periodic renewal, and ongoing updates to application information. FINTRAC must also maintain a public roll of enrolled entities. For businesses that have operated without a FINTRAC profile, this is a significant change in supervisory visibility.

When Does FINTRAC Enrolment Take Effect?

FINTRAC’s modernization roadmap states that universal enrollment comes into force in line with regulations to be published in the Canada Gazette, Part II. FINTRAC has said it will provide information on enrollment as it becomes available. Other Bill C-12 changes are already in effect, as the table shows.

How Enrolment, Renewal, and Revocation Work

The framework covers the full enrolment lifecycle. Regulations will prescribe the details, but the legislation sets out these core requirements:

• Application: Reporting entities apply to FINTRAC in the prescribed form.
• Renewal: Enrolment expires after a prescribed period, and entities must renew before it does.
• Change notices: Entities must tell FINTRAC of changes to their information within 30 days of becoming aware of the change.
• Information requests: Entities must respond to FINTRAC requests for clarification or information.
• Denial or revocation: FINTRAC can deny or revoke enrolment, with review and appeal rights to the Federal Court.

The revocation risk deserves close attention. Legal analysis of the framework indicates that FINTRAC may revoke enrolment if an entity does not respond to an information request within 30 days. FINTRAC can also deny or revoke enrolment where an entity has committed a violation and failed to pay the resulting penalty. A revocation could disrupt operations, so response procedures should be built before enrollment begins.

Penalty Context for Reporting Entities

Enrolment arrives alongside a tougher enforcement framework. According to FINTRAC’s guidance on the new penalty framework, the maximum administrative monetary penalties (AMPs) rise to up to 40 times current limits. FINTRAC will also consider ability to pay, require mandatory compliance agreements for prescribed violations, and use compliance orders as an additional tool. BLG’s analysis of the amendments reports maximums of $40,000 for minor violations, $4 million for serious violations, and $20 million for very serious violations.

These changes apply to violations that occur after March 26, 2026. Compliance orders can be publicized, and breaching one is a separate violation under the Act. For a business that has never dealt with FINTRAC directly, the combined effect is a much higher cost of non-compliance.

Preparing for FINTRAC Enrolment Now

Regulations are pending, yet several steps are useful today. Starting early is practical because enrollment will add a recurring calendar of renewals and notices to existing compliance work:

1. Confirm your status. Review the definitions in the PCMLTFA and the Canadian AML laws and regulations to determine whether you are a reporting entity and whether an exception or existing MSB registration applies.
2. Assign ownership. Name a responsible person for the application, renewals, and change notices, with a designated backup.
3. Collect core business information. Legal names, addresses, ownership details, and contacts will likely be needed, and the regulations will confirm the exact data.
4. Build a 30-day response process. Route FINTRAC correspondence to monitored mailboxes and log every request with a due date.
5. Test your compliance program. Confirm it is reasonably designed, risk-based, and effective, as described in this overview of an AML compliance program.
6. Follow FINTRAC updates. The FINTRAC guidance and advisories archive is a useful place to track new publications.

Building an Enrollment-Ready Compliance Program

FINTRAC enrollment turns a set of obligations that many businesses managed quietly into an ongoing relationship with the regulator. Renewals, change notices, and 30-day response windows reward organizations with clear ownership and organized records. Entities that already centralize reporting and documentation, for example through a regulatory reporting solution, will find these routines easier to sustain. Preparing now, while the regulations are still pending, gives reporting entities time to close gaps before enrollment begins.