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27 January 2026

Why 2026 Will Be A Make-or-break Year For Financial Innovation In Canada

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Gowling WLG

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After a stop-start digital and financial services policy cycle in 2025, Canada is entering 2026 with renewed momentum and clearer intent. With Budget 2025 laying the groundwork for modernization...
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After a stop-start digital and financial services policy cycle in 2025, Canada is entering 2026 with renewed momentum and clearer intent. With Budget 2025 laying the groundwork for modernization, the coming year will be defined by execution: translating policy ambition into functioning frameworks for privacy, AI, payments and digital finance.

For fintechs, financial institutions and technology providers, 2026 won't just be about keeping up with compliance; it will be about positioning early for a more connected, data-driven and real-time financial system.

Open banking: From concept to compliance

Consumer-driven (aka "open") banking is poised to move decisively from policy vision to reality in 2026. With the data mobility right as its foundation, enshrined in amendments to Canadian privacy legislation, and a proposed Consumer Driven Banking Act expected to be enacted early in 2026, attention will shift to implementation details that will be set out in the regulations. The government has announced its plan to launch the framework in 2026 and expand it to "write access" by mid-2027, which will be contingent on the launch of the Real-Time Rail.

Real-Time Rail: The payments backbone arrives

Canada's Real-Time Rail is scheduled to go live this year, fundamentally reshaping Canada's payments landscape. By enabling instant, irrevocable and data-rich transactions domestically (and, in time, internationally), the system will do more than modernize payments; it will serve as critical infrastructure for consumer-driven banking and support that advancement of capabilities such as payment initiation ("write access").

Privacy reform: Back with teeth

Federal privacy reform is ready for a reboot following the collapse of Bill C-27, with new legislation expected to strengthen individual rights, modernize consent and significantly expand enforcement powers. Crucially, privacy will no longer sit in isolation, but will intersect directly with data mobility, digital sovereignty and sector-specific initiatives like open banking and AI, raising the stakes for organizations that rely on large-scale data use or cross-border data flows.

Continued focus on AML/ATF

Canada's AML/ATF agenda is expected to maintain momentum in 2026, with the Carney government continuing to prioritize reforms to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. Plans to introduce AML/ATF amendments originally as part of the draft Strong Borders Act (Bill C-2) were scrapped in 2025. However, these amendments re-appeared unchanged in Bill C-12, which dropped some of the more controversial unrelated proposals. The government continues to focus on disrupting cash-based laundering and strengthening information-sharing pathways, building on earlier amendments to Canada's AML/ATF regime. Looking ahead, Ottawa has committed to introducing legislation by Spring 2026 to launch a new Financial Crimes Agency to serve as Canada's lead enforcement body for complex financial crimes.

Stablecoins: Moving the ball forward

With a draft national legislative framework for Canadian dollar-backed stablecoins now released and Senate committee hearings conducted, stablecoins are set to graduate from Budget 2025 commitments to actionable regulation in 2026. As policymakers and the Bank of Canada integrate stablecoins with existing payments and AML regimes, issuers will need to ensure assets are one-to-one backed with cash and high-quality liquid assets, and users have clear redemption rights.

At the provincial level, the first regulated Canadian dollar stablecoin offered by way of a registered prospectus has been approved by Canadian securities administrators. With both provincial securities regulators and federal authorities asserting jurisdiction, whether Canada ultimately moves towards a harmonized national framework or accepts dual-track oversight remains an open, and strategically important, question. Learn how to position yourself for success in Canada's new stablecoin era.

Tokenized deposits: Early signals, growing momentum

While not yet a formal regulatory category, tokenized deposits are increasingly part of policy and supervisory discussions alongside stablecoins. Bank deposits represented on blockchain technology raise questions about how existing banking, prudential and deposit insurance frameworks apply when traditional liabilities are represented digitally.

In 2026, regulators may meaningfully explore how tokenized deposits fit within Canada's financial system. As Real-Time-Rail, blockchain-based payment rails and open banking mature, the tokenization of deposits and various other types of traditional assets could become a natural extension of programmable, real-time finance. For banks, fintechs, adopters and market infrastructure providers, early engagement and technical readiness may offer a competitive advantage as Canada's digital money framework continues to evolve.

Lowering the barriers to entry in Canadian banking

As sector dynamics shift with innovation, Canada's banking landscape is moving towards greater competition and a more streamlined path to market entry. Last year, OSFI signalled a willingness to revamp its approvals processes and "mature" its tolerance to risk to support more timely entry of new players, particularly in recognition of the rapid developments in digital money. This year, expect to see further indications that the market is evolving, as these shifts in rhetoric translate into practical changes for prospective entrants.

Canada's AI future: Strategy refresh coming, legislation on hold

Canada's refreshed AI strategy is expected to be released in 2026, while the government has indicated no intention to revive a dedicated AI legislation. Hear what industry leaders are saying about Canada's AI opportunity.

Other areas worth watching

Beyond headline reforms, several adjacent policy threads will shape the operating environment. Cybersecurity obligations, particularly for critical systems, are likely to expand, with implications for payments and AI infrastructure. Online harms and lawful access initiatives may influence how organizations manage data, content and government requests. At the same time, digital sovereignty, interoperability standards and escalating fraud risks will push the financial sector to rethink how technology can be used to protect consumers while enabling innovation.

Looking ahead

This year is shaping up to be a hinge year for Canada's digital and financial ecosystem. With major legislation advancing and foundational infrastructure coming online, the organizations that thrive will be those that view regulation not as friction, but as architecture—something to build on, not around. The next 12 months will reward preparedness, strategic foresight and a willingness to engage early in shaping what comes next.

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