Ontario, Canada

Crypto Licensing

Ontario's crypto asset trading platform licensing framework continues to operate through registration as a Restricted Dealer or Investment Dealer under the Securities Act (Ontario) and National Instrument 31-103, or through operation under a Canadian Securities Administrators pre-registration undertaking, for platforms serving Ontario clients. This registration/pre-registration-undertaking structure is the core access pathway, and this cycle's evidence confirms it remains both operative and actively enforced.

The Ontario Securities Commission's investor-warnings notice covering September 22 to October 14, 2026 lists unregistered entities Risance Ltd. and Smjer Fundark, indicating continued identification of platforms operating outside the registration perimeter. Separately, an active Capital Markets Tribunal proceeding against Wesley William Robinson and DRR900306 NS Ltd. is underway under sections 127(1) and 127(4.0.2) of the Securities Act, reflecting formal adjudicative enforcement distinct from the investor-warning mechanism. Together these two tracks, public investor warnings and a formal Tribunal proceeding, indicate the OSC is pursuing registration-perimeter enforcement on multiple fronts concurrently.

For platforms pursuing registration under the Investment Dealer category specifically for crypto asset trading platforms, the Canadian Investment Regulatory Organization imposes a CAD 40,000 entrance fee in addition to the underlying National Instrument 31-103 registration obligations, representing a discrete financial threshold layered onto that particular registration pathway.

The overall picture is of a registration regime that is well-established in structure but subject to continuing enforcement attention: the OSC's own key judgment on the evidence is that it remains the most enforcement-active Canadian Securities Administrators member on crypto, evidenced this cycle by the concurrent Tribunal proceeding, investor-warnings notice, and (separately tracked) amended exemptive-relief decision for a registered platform.

Outlook

The Capital Markets Tribunal proceeding against Wesley William Robinson and DRR900306 NS Ltd. remains open, with no resolution date available on current evidence. Whether further entities will be added to future OSC investor-warnings notices cannot be forecast, but the pattern across this cycle suggests registration-perimeter enforcement will likely remain active. The CAD 40,000 CIRO entrance fee for the Investment Dealer crypto asset trading platform category remains a standing cost consideration for platforms evaluating that specific registration route.

Stablecoin Regime

Canada's federal Stablecoin Act, enacted through Bill C-15 and granted Royal Assent on 26 March 2026, establishes a dedicated regulatory classification for fiat-backed stablecoins. Where a stablecoin meets the Act's tests, including a 1:1 reserve of high-quality liquid assets, at-par redemption, and issuance by a registered issuer, it is treated as a regulated payment instrument under Bank of Canada supervision rather than as a security. This is a deliberate jurisdictional choice: it removes qualifying fiat-backed stablecoins from provincial securities-law treatment and places them instead under a single federal supervisor, the Bank of Canada. Non-fiat-backed stablecoins, including algorithmic, commodity-backed and crypto-collateralised designs, are explicitly excluded from this federal treatment and remain classified as crypto contracts or value-referenced crypto assets under provincial securities law, meaning Ontario market participants dealing in these instruments continue to face OSC/CSA oversight rather than Bank of Canada supervision.

The substantive reserve and redemption requirements are significant even though the regime is not yet operative. Issuers must maintain reserves segregated and held with a qualified custodian, matching assets 1:1 against outstanding stablecoins in high-quality liquid form. Issuers must also offer redemption at par and disclose redemption conditions fully, including timing and any applicable fees, addressing a common source of stablecoin-holder risk where redemption terms are opaque or discretionary. Non-prudentially-regulated issuers face an additional gate: before issuing stablecoins in Canada, they must apply to be listed on a public registry maintained by the Bank of Canada. This registry function has not yet been established, and the Act's regulatory stage remains enacted but not yet effective, with implementing regulations still in development.

Outlook

The critical near-term milestone is the publication of implementing regulations, expected around the first quarter of 2027, which would operationalise both the Bank of Canada's public registry and the detailed compliance mechanics for issuers. Until that registry exists, the Act's substantive protections (reserve segregation, at-par redemption, registry-based gatekeeping) remain enacted law without an operative enforcement or registration pathway. Market participants evaluating stablecoin issuance targeting Ontario or Canadian users should treat the current period as a design-and-preparation window rather than one in which registration is actually available.

Consumer Protection

CIRO's Digital Asset Custody Framework, published as Guidance Note 26-0033 and effective 3 February 2026, is the most consequential consumer-protection development for Ontario crypto-asset trading platform users in this period. The framework imposes tiered custody and segregation requirements on CIRO dealer members operating crypto-asset trading platforms: digital assets must be held with an approved custodian or under approved internal custody arrangements, with internal custody capped at 20% of assets, Tier 3 external custodians capped at 75%, and Tier 4 external custodians capped at 40%. Stablecoins are treated as tokenized assets for the purposes of these custody rules rather than as cash-equivalent instruments, which has implications for how dealer members structure stablecoin holdings on behalf of clients. The framework is enforced through CIRO membership terms rather than through a standalone CIRO Rule, meaning compliance is a condition of continued CIRO membership for dealer members operating these platforms. The explicit policy rationale behind the tiered caps is to prevent a repeat of the custody failure that followed the collapse of QuadrigaCX, where commingled and poorly controlled custody arrangements left client assets unrecoverable.

Separately, advertising and marketing conduct by crypto-asset trading platforms, both OSC-registered and unregistered, remains governed by Joint CSA Staff Notice guidance on advertising, marketing and social-media practices. False or misleading advertising by a platform is treated by the OSC as a factor bearing on registration fitness, linking marketing conduct directly to a platform's ongoing ability to operate under its registration or pre-registration undertaking. This marketing-conduct guidance is non-binding in form but carries practical weight because of its connection to registration status.

Outlook

With the custody framework now in force and enforced through membership terms, the principal consumer-protection question going forward is one of consistent application across dealer members as trading volumes and platform consolidation (illustrated by the Robinhood-WonderFi transaction) continue. No Canada-specific crypto market-abuse statute analogous to MiCA Title VI has been located, which leaves a structural gap in market-conduct protections alongside the now-functioning custody regime.