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Overview
Bill C-15, the Budget Implementation Act, 2025, No. 1 (the “2025 Budget Act”), received Royal Assent on March 26, 2026. The 2025 Budget Act has expanded the mandate of the Bank of Canada (the “Bank”) to include the supervision of stablecoin issuers under the Stablecoin Act and oversight of the framework for consumer-driven banking framework under the Consumer-Driven Banking Act. The Department of Finance will collaborate with the Bank to support the development and implementation of these two new regulatory regimes for the financial services sector.
Canada’s Stablecoin Framework
The Stablecoin Act presents the first comprehensive attempt to regulate the issuance of fiat-backed stablecoins in Canada. It imposes duties on entities that create stablecoins and make them available for purchase, directly or indirectly, by persons in Canada.
The Department of Finance has noted that the goal of the stablecoin regulatory framework is to promote safe innovation and competition in the financial sector, while ensuring that consumers are protected. The framework will apply to domestic and foreign issuers, as such term is defined in the Stablecoin Act.
Stablecoin issuers will be required to, among other things:
- register with the Bank, provide necessary information on an ongoing basis and as requested, and be subject to prudential requirements overseen by the Bank;
- maintain a 1:1 reserve of high-quality liquid assets, in the reference currency of the stablecoins;
- create and adhere to a redemption policy for stablecoin holders, and offer at-par redemption;
- create and adhere to policies around corporate governance, risk management, data security, and recovery and resolution.
The Stablecoin Act sets out the objects of the Bank in respect of stablecoin, which are to:
- supervise issuers in order to determine whether they are in compliance with the Act;
- promote the adoption by issuers of policies and procedures that are designed to implement their duties under the Act; and
- monitor and evaluate trends and issues related to stablecoins.
Canada’s Consumer-Driven Banking Framework
Consumer-driven banking, also known as open banking or consumer-directed finance, refers to applications that allow consumers and small businesses to securely transfer their financial data to approved service providers of their choice. As stated by the Department of Finance, the goal of Canada's consumer-driven banking framework is to promote innovation in the financial sector, improve financial outcomes for Canadians, and ensure that consumers can share their data securely.
The Consumer-Driven Banking Act addresses, among other things, accreditation, national security, data sharing, security safeguards, consent, authentication, liability, complaints, administration and enforcement and the prohibition of screen scraping.
Participation will initially be mandatory for some banks, based on a threshold for retail volume that has yet to be specified. Remaining federally regulated financial institutions, as well as credit unions, crown corporations acting as banks, registered payment service providers, and other entities seeking accreditation will be able to opt-in if they meet certain entry requirements and can demonstrate compliance with prescribed technical and security specifications. This means that banks and other accredited entities will be required to share financial data, as directed by their customers.
Third-party entities will also need to be accredited to obtain or manage consumers’ consent on behalf of participating entities, confirm consumers’ authentication information or manage the authentication of consumers on behalf of participating entities, and provide or receive consumer data on behalf of participating entities.
The Bank’s objects under the Consumer-Driven Banking Act are to:
- supervise participating entities, accredited third-party service providers, the external complaints body, and the technical standards body to determine whether they are in compliance with the Act, regulations and orders, undertakings, compliance agreements, and directions under the Act;
- monitor and evaluate trends and emerging issues that may have an impact on consumers of consumer-driven banking, including trends and issues in respect of products, services and market developments, and make information on those trends and issues public;
- foster participation in consumer-driven banking in cooperation with any department, agency or agent corporation of the Government of Canada or any department, agency or agent or mandatary corporation of the government of a province, financial institutions and consumer and other organizations; and
- foster competition in the financial sector in the interests of consumers.
Looking Ahead
Although the Bank’s expanded mandate became effective when the 2025 Budget Act received Royal Assent, it will take several years for the full regulatory frameworks to be completed and fully in force.
On March 26, 2026, the Bank noted that it will continue preparatory work to support the implementation of these new mandates over the coming months, including (i) contributing to the development of regulations, (ii) developing supervisory policies and guidelines, (iii) engaging with industry and other stakeholders, and (iv) preparing operational frameworks for oversight. The Bank will share further details on regulatory timelines and consultation opportunities as they become available.
Fasken’s Financial Services group is actively monitoring regulatory developments in this area.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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