Canada — License Map

June 6, 2026

25 min read

Canada regulates digital assets through a combination of federal and provincial authorities rather than a single dedicated crypto framework. The Canada Revenue Agency (CRA) treats cryptocurrency as a commodity under the Income Tax Act, making all crypto dispositions taxable events subject to either capital gains or business income treatment. There is no standalone cryptocurrency legislation; instead, crypto is governed by the Income Tax Act (income and capital gains), the Excise Tax Act (GST/HST), provincial securities regulations (trading platforms), and FINTRAC regulations (AML/KYC).

On the licensing side, the Canadian Securities Administrators (CSA) requires crypto trading platforms operating in Canada to register as investment dealers or restricted dealers (formalized through CSA Staff Notice 21-327). FINTRAC classifies crypto exchanges and dealers as money services businesses (MSBs), requiring registration, KYC procedures, record-keeping, and suspicious transaction reporting under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).

Canada is actively implementing the OECD CARF framework, with an effective date of January 1, 2026 and first international exchange of information expected in 2027. The CRA has significantly intensified crypto tax enforcement, with 35 dedicated auditors, over 230 active audit files, and $100 million collected from crypto audits over three years. An estimated 40% of crypto platform users have been flagged for tax evasion or high non-compliance risk.

Regulatory Architecture

RegulatorRoleKey Authority
Canada Revenue Agency (CRA)Primary tax authority; crypto tax assessment and enforcementIncome Tax Act
Canadian Securities Administrators (CSA)Securities regulation; crypto trading platform registrationCSA Staff Notice 21-327; provincial securities laws
FINTRACAML/KYC; MSB registration for crypto exchanges and dealersPCMLTFA
OSFI (Office of the Superintendent of Financial Institutions)Oversight of financial institutionsFederal financial legislation
Provincial regulatorsProvincial income tax; energy regulation (e.g., Quebec Hydro-Quebec/Regie de l'energie for mining)Provincial legislation

Platform Registration (CSA)

The CSA requires crypto trading platforms operating in Canada to register as investment dealers or restricted dealers. This requirement was formalized through CSA Staff Notice 21-327.

Money Services Business Registration (FINTRAC)

Crypto exchanges and dealers must register with FINTRAC as MSBs:

  • KYC procedures required for all customers
  • Large cash transaction reports (LCTRs) for transactions of $10,000 or more
  • Suspicious transaction reports (STRs) when there are reasonable grounds to suspect money laundering or terrorist financing
  • Record-keeping and compliance obligations

Tax Reporting Obligations

Capital Gains vs. Business Income

The CRA distinguishes between capital gains and business income on a case-by-case basis:

  • Capital gains: Only 50% of the gain is taxable (the "inclusion rate")
  • Business income: 100% of profits are taxable at marginal rates

The proposed increase of the capital gains inclusion rate to 66.67% on gains above $250,000 (Budget 2024) was cancelled in March 2025. The 50% inclusion rate remains in effect for all taxpayers.

PeriodInclusion RateStatus
Pre-June 25, 202450%Standard rate
June 25, 2024 proposal66.67% for gains > $250KProposed in Budget 2024
January 31, 2025Deferred to January 1, 2026Announced by Finance Minister
March 21, 2025CancelledGovernment cancelled the increase

CRA Business Activity Indicators

Six factors the CRA uses to determine if crypto activity constitutes business income:

  1. Frequent buying and selling history
  2. Short holding periods with quick turnover
  3. Demonstrated knowledge of cryptocurrency markets
  4. Substantial time spent on market analysis
  5. Use of debt financing for purchases
  6. Advertising willingness to buy crypto-assets

Cost Basis Method

Canada requires the weighted average Adjusted Cost Base (ACB) method. Transaction fees (including gas fees) are added to the ACB on acquisition and deducted from proceeds on disposition. Capital losses: only 50% of capital losses can offset taxable capital gains; unused losses carry back 3 years or forward indefinitely.

Taxable Events

  • Selling crypto for fiat currency
  • Trading one crypto-asset for another (crypto-to-crypto)
  • Using crypto to purchase goods or services (barter transaction)
  • Gifting or donating crypto-assets

Non-taxable: Buying crypto with fiat, transferring between own wallets, holding (unrealized gains).

Mining and Staking

Mining is generally treated as a business activity -- mined coins reported as business income at FMV in CAD on the date received. Mining equipment may qualify for Capital Cost Allowance (CCA) deductions under CCA Class 50. Electricity and operational costs are deductible as business expenses.

Staking rewards are taxed as income at FMV in CAD when received. Subsequent disposition creates a separate capital gain or loss event.

DeFi: The CRA has not issued specific DeFi guidance as of March 2026.

Reporting Forms

FormPurposeDeadline
Schedule 3Capital gains/losses from cryptoApril 30
Form T2125Business income from crypto activitiesApril 30 (June 15 for self-employed, but tax owing due April 30)
Form T1135Foreign income verification (if specified foreign property > $100,000 CAD)April 30

T1135 ambiguity: The CRA has provided limited guidance on whether crypto-assets constitute specified foreign property. Crypto held through a Canadian CSA-regulated platform is generally not considered specified foreign property. Crypto on foreign exchanges or in self-custody wallets managed outside Canada may trigger T1135 filing.

OECD CARF Implementation

MilestoneDate
Canada endorsed CARF joint statementNovember 10, 2023
Draft legislative proposals releasedAugust 15, 2025
Public consultation closedSeptember 12, 2025
CARF effective dateJanuary 1, 2026
First reporting periodCalendar year 2026
First exchange of information2027

Under CARF, crypto-asset service providers (CASPs) must report annually to the CRA: user identification data, transaction data (crypto-to-fiat, crypto-to-crypto, transfers exceeding US$50,000). Covers cryptocurrencies, stablecoins, NFTs, and blockchain-based payment/investment instruments.

Enforcement

MetricDetail
Dedicated crypto auditors35
Active audit files230+
Taxes collected (3 years)$100 million
Users flagged for evasion/non-compliance risk40% of crypto platform users

Notable enforcement actions:

  • Dapper Labs probe: CRA obtained a court order for data on 2,500 users of Dapper Labs (NBA Top Shot, CryptoKitties)
  • Criminal investigations: Five investigations with a digital asset component initiated between 2020 and Q1 2025 (four ongoing); no criminal charges filed as of March 2025

The CRA has acknowledged: "There is no way to reliably identify taxpayers operating in the crypto space and assess compliance." The anticipated financial-crimes legislation arrived in March 2026: Bill C-12 (Royal Assent 26 March 2026) sharply raised PCMLTFA administrative monetary penalties (see Payment / Transfer Service Licensing).

Regulatory Direction

Canada's regulatory trajectory is characterized by increasing enforcement capacity and international alignment:

  • CARF effective (January 1, 2026): CASPs must begin collecting user and transaction data
  • Stablecoin Act enacted (26 March 2026): Federal fiat-referenced-stablecoin regime (Bill C-15, Div. 45 Pt. 5) under Bank of Canada; not yet in force, coming into force by Governor-in-Council order expected 2027
  • AML penalties raised (Bill C-12, 26 March 2026): FINTRAC AMP ceilings lifted ~40x (to C$20M very serious); the previously-anticipated "Spring 2026" financial-crimes legislation has now been enacted
  • 2027: First CARF information exchange with partner jurisdictions; Stablecoin Act expected coming-into-force
  • Capital gains inclusion rate: Remains at 50% with no pending proposals to change
  • DeFi guidance gap: No specific CRA guidance on DeFi, wrapped tokens, or bridging -- a significant area of uncertainty
  • T1135 ambiguity: Foreign-held crypto classification remains unclear
  • Quebec mining energy: Hydro-Québec applies a dedicated Rate CB ("Tarif CB") to medium- and large-power contracts where installed capacity for cryptographic use applied to blockchains is ≥50 kW. Under the 2026 Electricity Rates schedule (effective 1 April 2026), authorized energy consumption is billed at tiered rates (medium-power: 6.061¢/kWh up to 210,000 kWh/month, then 4.495¢/kWh; large-power: 4.165¢/kWh) and energy consumption above or other than authorized consumption is billed at 18.078¢/kWh (rising to 18.767¢/kWh the following rate year, +3.8%) (Hydro-Québec 2026 Electricity Rates chart, eff. 1 April 2026). Hydro-Québec has further proposed to the Régie de l'énergie an adjustment averaging ~19.5¢/kWh for blockchain cryptographic use, expected to take effect in the second half of 2026 subject to Régie approval, with a three-year transitional rate for existing customers (Hydro-Québec press release)

Canada's approach is broadly similar to the US in treating crypto as property but differs in requiring the ACB (weighted average) method rather than allowing FIFO/LIFO/specific identification, and the 50% inclusion rate results in lower effective capital gains tax rates than many jurisdictions.

RWA / Security Token Platform Licensing

Canada regulates tokenized real-world assets through the Canadian Securities Administrators (CSA) framework, with provincial securities regulators overseeing registration and compliance. Tokenized securities that meet the definition of securities under provincial securities legislation require registration for dealing, advising, and marketplace operation. The CSA has been transitioning crypto trading platforms (CTPs) from interim restricted dealer status to full investment dealer registration with CIRO membership.

License Details

AttributeDetail
License name(s)Investment Dealer registration (CIRO membership, replacing restricted dealer); Exempt Market Dealer (EMD) for distributing exempt-market securities; Investment Fund Manager (for tokenized fund products); Marketplace (ATS) registration under NI 21-101
Regulatory authorityCSA (provincial securities regulators: OSC, AMF Quebec, BCSC, ASC); CIRO (investment dealer oversight)
Legal basisProvincial securities legislation; National Instruments (NI 31-103, NI 21-101, NI 45-106); CIRO rules

Requirements

CategoryCapitalDescription
Restricted Dealer (phased out)CAD 50,000 minimumTime-limited interim registration for CTPs; being discontinued
Investment DealerHigher, CIRO-determinedFull registration with CIRO membership; now required for CTPs
Exempt Market DealerCAD 50,000+For distributing exempt-market securities, including tokenized offerings
Marketplace (ATS)Subject to NI 21-101For platforms facilitating secondary trading of tokenized securities

Prospectus Exemptions for Tokenized Securities

Under National Instrument 45-106, tokenized securities may be distributed without a prospectus under several exemptions:

ExemptionInvestor Limits
Accredited Investor (s. 2.3)No investment limits; accredited investor criteria apply
Offering Memorandum (s. 2.9)CAD 10,000/year (retail); CAD 30,000/year (eligible); CAD 100,000 with suitability advice
Private Issuer (s. 2.4)Closely held issuers with limited shareholders
Start-up CrowdfundingCAD 250,000 per offering in participating jurisdictions

Key Market Activity

  • OSC LaunchPad (May 2025): announced major initiative for tokenized long-term asset funds covering venture capital, private equity, private credit, and infrastructure
  • CIRO published a Digital Asset Custody Framework for dealer members operating CTPs
  • CSA and CIRO (August 2024): announced CTPs must transition from restricted dealer to investment dealer registration

Transition

The CSA framework is maturing rapidly. The transition from restricted dealer to investment dealer status represents a significant step toward treating tokenized asset platforms equivalently to traditional securities intermediaries. CIRO's Digital Asset Custody Framework provides clear expectations for custody of digital assets by dealer members. The OSC LaunchPad initiative signals growing regulatory support for tokenized fund products.

See

Canada RWA Regulation for full details on CSA registration requirements, CIRO investment dealer transition, prospectus exemptions, OSC LaunchPad, and provincial approaches.

DeFi Protocol Licensing

Canada has no DeFi-specific regulatory framework. DeFi activities are assessed through existing securities, derivatives, and AML legislation. The CSA applies a substance-over-form approach -- if a DeFi protocol performs functions equivalent to a registered dealer or marketplace, registration may be required. The OSC/Bank of Canada AMM Discussion Paper (July 2024) was the first dedicated DeFi-focused regulatory analysis from Canadian authorities.

Available License Types for DeFi Operations

LicenseAuthorityCapitalDeFi Relevance
FINTRAC MSB registrationFINTRACNone specifiedRequired for entities "dealing in virtual currency"; unclear if truly decentralized protocols trigger MSB obligations
CSA Restricted Dealer (being phased out)Provincial securities regulatorsCAD 50,000 minimumTime-limited interim registration for crypto trading platforms
CSA Investment Dealer (CIRO membership)Provincial regulators / CIROHigher, CIRO-determinedNow required for crypto trading platforms; replaces restricted dealer
Marketplace (ATS) registrationProvincial regulatorsSubject to NI 21-101For platforms facilitating secondary trading; potentially applicable to DeFi AMMs

Application Timeline

  • FINTRAC MSB registration: 2--8 weeks; no fees
  • CSA Restricted Dealer: 6--18 months (Ontario and Quebec most stringent)
  • CSA Investment Dealer: Longer timeline due to CIRO membership requirements
  • DeFi-specific: No dedicated pathway; assessed under existing tracks

DeFi-Specific Requirements

  • CSA Staff Notice 21-327: Securities legislation may apply to crypto trading platforms (including decentralized ones) if the user's contractual right to a crypto asset constitutes a security or derivative (OSC)
  • AMM Discussion Paper (July 2024): OSC/Bank of Canada analyzed Uniswap, Curve, Sushiswap, Balancer; concluded "a limited set of AMM activities may already be captured within existing regulatory frameworks" (Bank of Canada, Staff Discussion Paper 2024-12)
  • No DAO legislation: Unincorporated DAOs risk classification as general partnerships under provincial Partnership Acts, with joint and several liability for all members
  • DeFi tax gap: CRA has not published specific DeFi guidance; yield farming, LP tokens, governance token rewards assessed under general commodity principles with significant uncertainty (Koinly guide)
  • Stablecoin Act enacted (not in force): The federal Stablecoin Act was enacted via Bill C-15 (Budget Implementation Act, 2025, No. 1), Division 45 of Part 5, Royal Assent 26 March 2026, with the Bank of Canada as primary regulator; substantive provisions come into force on a day fixed by order of the Governor in Council (expected 2027) (Parliament of Canada — Bill C-15 Royal Assent)
  • Bill C-12 (Royal Assent 26 March 2026): Raised FINTRAC administrative monetary penalties ~40x to CAD 40,000 (minor) / CAD 4 million (serious) / CAD 20 million (very serious) per violation (up from the prior CAD 500,000 entity ceiling), added a "reasonably designed, risk-based and effective" compliance-program violation, and introduced mandatory public compliance orders. (Bill C-2, Strong Borders Act, a separate measure proposing a CAD 10,000 cash-acceptance restriction, remains before Parliament and is NOT enacted)

Key Enforcement

  • Bybit (June 2022): OSC ordered disgorgement of USD 2,468,910 for operating unregistered crypto trading platform
  • KuCoin (June 2022): CAD 2,000,000 penalty; permanent market ban
  • Binance (2024): CAD 6+ million FINTRAC penalty; withdrew from Canada
  • No DeFi-specific enforcement as of March 2026; enforcement focused on centralized platforms

Operators with DeFi Relevance

FirmRegistrationActivity
Wealthsimple CryptoCSA Investment DealerRegistered CTP; expanding digital asset offerings
BitbuyCSA registeredMajor Canadian exchange
NewtonCSA registeredCanadian crypto exchange

For comprehensive DeFi regulation analysis, see

Canada DeFi Regulation.

Insurance / Risk Transfer Licensing

Overview

Canada does not have a mandatory insurance requirement specific to crypto businesses. However, the regulatory framework creates indirect insurance obligations through CIRO (Canadian Investment Regulatory Organization) membership requirements for investment dealers operating crypto trading platforms. Insurance is a gating factor for CIRO custody tiers, making it a practical necessity for platforms seeking to hold client digital assets. The Canada Deposit Insurance Corporation (CDIC) explicitly excludes crypto-asset holdings from deposit protection coverage.

Regulatory Authority

BodyRole
OSFI (Office of the Superintendent of Financial Institutions)Oversees financial institutions including federally regulated insurers; sets prudential standards
CIRO (Canadian Investment Regulatory Organization)Sets custody and insurance requirements for investment dealer members operating crypto trading platforms
Provincial insurance regulatorsLicense and supervise insurance companies and intermediaries at the provincial level
CDICDeposit insurance for member institutions; explicitly excludes crypto assets

Insurance Requirements for Crypto Businesses

DimensionDetail
CIRO custody tiersCIRO's Digital Asset Custody Framework establishes tiered custody requirements where insurance coverage is a key differentiator; higher custody tiers (permitting larger client asset holdings) require proportionally greater insurance or bonding arrangements
Investment dealer bondingCIRO member firms must maintain financial institution bonds and fidelity insurance as a condition of membership
FINTRAC MSB registrationMSB registration does not carry insurance requirements
CSA platform registrationNo standalone insurance mandate; insurance requirements flow from CIRO membership for investment dealers
CDIC exclusionCDIC covers eligible deposits at member institutions up to CAD 100,000 per depositor per insured category; crypto-asset holdings are explicitly excluded
CIPF protectionThe Canadian Investor Protection Fund covers client assets held by CIRO dealer members (up to CAD 1 million per account category) in the event of member insolvency; applicability to crypto assets held by registered CTPs is evolving

Insurance as Custody Gating Factor

CIRO's Digital Asset Custody Framework creates a practical hierarchy where insurance directly impacts a platform's operational scope:

  • Platforms with comprehensive insurance coverage qualify for higher custody tiers, enabling them to hold larger volumes of client digital assets
  • Platforms without adequate insurance are restricted to lower custody tiers with more stringent cold storage and segregation requirements
  • This framework effectively makes insurance a competitive differentiator among Canadian crypto trading platforms

Regulatory Direction

  • The transition from restricted dealer to full investment dealer registration (CSA/CIRO) is increasing insurance expectations for crypto trading platforms
  • OSFI has not issued specific guidance on insurance requirements for digital asset custodians outside the CIRO framework
  • No expansion of CDIC deposit guarantee to cover crypto assets is under consideration
  • Provincial insurance regulators have not created crypto-specific insurance product categories

Cross-Reference

See

Canada Digital Asset Insurance for full details on CIRO custody tier insurance requirements, OSFI oversight, CDIC exclusion, CIPF applicability, and provincial insurance regulation.


NFT & Digital Collectibles

DimensionDetail
Applicable licence(s)Restricted Dealer Registration (Crypto Asset Trading Platform); FINTRAC MSB Registration
Regulatory authorityProvincial/territorial securities commissions (coordinated by CSA); FINTRAC
Capital requirementsCAD 100,000 minimum net capital (Restricted Dealer per NI 31-103); no minimum for MSB
Timeline (actual)6-18 months (Restricted Dealer, PRU process); ~30 days (FINTRAC MSB)
Key requirementsNRD filing with business plan, compliance manual, AML programme; UDP and CCO with proficiency requirements; annual audited financial statements; quarterly financial reporting
NFT-specific notesPure collectible NFTs generally not classified as securities; NFTs with investment features, profit-sharing, or fractional ownership may be investment contracts triggering Restricted Dealer registration
Cross-reference
Full NFT regulation details

Payment / Transfer Service Licensing

Overview

Canada regulates crypto payment services through a multi-layered framework: FINTRAC MSB registration (AML/CTF), the Retail Payment Activities Act (RPAA) for payment service providers (effective November 2024), and provincial CSA securities registration for trading platforms. The federal Stablecoin Act — enacted via Bill C-15 (Division 45, Part 5), Royal Assent 26 March 2026 but not yet in force (expected 2027) — establishes Bank of Canada oversight for fiat-referenced stablecoin issuers.

DimensionDetail
Licence nameFINTRAC MSB registration; RPAA Payment Service Provider (PSP) registration; CSA Investment Dealer registration (CIRO membership); Stablecoin Act issuer registration (Bank of Canada public registry, on coming-into-force)
Enabling statutePCMLTFA (AML/MSB); Retail Payment Activities Act (RPAA, November 2024); Stablecoin Act (Bill C-15, Div. 45 Pt. 5, Royal Assent 26 March 2026, not yet in force); provincial securities legislation
Regulatory authorityFINTRAC (AML); Bank of Canada (RPAA/Stablecoin Act); CSA/CIRO (securities); CRA (tax)
Capital requirementFree (FINTRAC MSB); C$2,500 non-refundable application fee (RPAA PSP); CAD 50,000+ (CSA CIRO-member dealer); Stablecoin Act reserve/capital detail deferred to forthcoming regulations
Timeline (actual)2--8 weeks (FINTRAC MSB); 6--18 months (CSA restricted/investment dealer); RPAA registration ongoing
Setup cost (excl. capital)CAD 50,000 -- CAD 200,000 (legal, compliance, AML programme)
Annual ongoing costCAD 80,000 -- CAD 300,000 (compliance, reporting, audit)
PassportingNone -- domestic framework only
Banking accessChallenging -- Canadian banks remain cautious; Wealthsimple Crypto, Bitbuy, Newton operate with banking relationships through CSA registration
Key holdersWealthsimple Crypto (CSA investment dealer); Bitbuy; Newton; 80+ FINTRAC MSB registrations revoked across 2025-Q1 2026 enforcement rounds
StatusFINTRAC MSB registration operational; RPAA PSP registration effective November 2024 (registration window closed 15 November 2024, transition period ended 7 September 2025); Stablecoin Act (Bank of Canada oversight) enacted (Royal Assent 26 March 2026) but not yet in force

Stablecoin framework (enacted, not in force): Bank of Canada as primary regulator; mandatory application for inclusion on a Bank of Canada public registry before issuance; 1:1 reserve mandate in reference currency and HQLAs; segregated qualified-custodian accounts protected from creditor claims; yield/interest prohibition; monthly reporting; national security review of applications. Substantive provisions come into force by order of the Governor in Council (expected 2027); specific penalty and reserve/capital dollar amounts remain deferred to forthcoming regulations and are NOT VERIFIED as published. As of 2026-06-06 no Stablecoin Act regulations have been located in the Canada Gazette; the Department of Finance's supporting regulations are expected to be published in the Canada Gazette for consultation during 2026 (industry estimates a 12–18-month process from early 2026), with the framework coming into force in 2027.

Enforcement escalation: FINTRAC imposed a C$176.9 million penalty against Xeltox Enterprises (operating as Cryptomus) in October 2025 — its largest-ever — and revoked 80+ crypto-linked MSB registrations across 2025-Q1 2026, including 51 in a single day on 24 March 2026. Bill C-12 (Royal Assent 26 March 2026) raised FINTRAC's maximum administrative monetary penalties ~40-fold to C$40,000 (minor) / C$4 million (serious) / C$20 million (very serious) per violation.

See

Canada Crypto Payment Regulation for full details on FINTRAC MSB, RPAA PSP registration, the enacted (not-in-force) Stablecoin Act, and CSA platform requirements.

For Full Details

  • Crypto Payment Regulation:
    Canada — Crypto Payment Regulation
    -- FINTRAC MSB, RPAA PSP, enacted (not-in-force) Stablecoin Act, CSA platform requirements
  • Digital Asset Taxation:
    Canada — Digital Asset Taxation
  • DeFi Regulation:
    Canada — DeFi Regulation
    -- CSA platform registration (Staff Notice 21-327), FINTRAC MSB, OSC/Bank of Canada AMM Discussion Paper, no DAO legislation, enforcement against unregistered platforms
  • RWA Regulation:
    Canada — RWA Regulation
    -- CSA registration framework, CIRO investment dealer transition, NI 45-106 prospectus exemptions, OSC LaunchPad tokenized funds, Digital Asset Custody Framework
  • Digital Asset Insurance:
    Canada Digital Asset Insurance
    -- CIRO custody tier insurance requirements, OSFI oversight, CDIC deposit exclusion, CIPF applicability, provincial insurance regulation
  • NFT & Digital Collectibles:
    Canada — NFT & Digital Collectibles
    -- CSA Restricted Dealer registration, FINTRAC MSB, securities classification for investment-feature NFTs, provincial coordination

Recent Licensing Developments (since 2026-03-20)

DateDevelopmentPrimary source
24 March 2026FINTRAC revoked 51 MSB registrations in a single day (~88% virtual-currency related); ~86 revoked across Q1 2026, raising the cumulative 2025-2026 total above 80FINTRAC (revocation listings); reconciled with
Canada — Crypto Payment Regulation
26 March 2026Bill C-15 (Budget Implementation Act, 2025, No. 1) received Royal Assent, enacting the Stablecoin Act (Division 45, Part 5) — first federal fiat-referenced-stablecoin regime under Bank of Canada; not yet in force, coming into force by Governor-in-Council order (expected 2027), with draft regulations to follow in the Canada GazetteParliament of Canada — Bill C-15 Royal Assent; Canada's Stablecoin Framework — Canada.ca
26 March 2026Bill C-12 received Royal Assent, raising FINTRAC AMPs ~40-fold to C$40,000 (minor) / C$4M (serious) / C$20M (very serious) per violation, adding a "reasonably designed, risk-based and effective" compliance-program violation and mandatory public compliance ordersReconciled with
Canada — Crypto Payment Regulation
(verified via DLA Piper, Blakes, McCarthy Tetrault)

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Verification Notes

This license-map file was reconciled against the refreshed (2026-06-04) source-domain files for Canada and re-verified on 2026-06-04 (prior modification: 2026-03-20). Operated under verification-standards.md Standard version 2026-06-04.

  • Stablecoin Act status: Verified against the refreshed
    crypto-payment
    and
    stablecoin
    source-domain files and the Parliament of Canada Bill C-15 Royal Assent page. Enacted via Bill C-15 (Division 45, Part 5), Royal Assent 26 March 2026; substantive provisions not yet in force (Governor-in-Council order expected 2027).
  • FINTRAC AMP ceiling: The Bill C-12 ~40x AMP increase (to C$20M very serious) and the new compliance-program violation are reconciled with the crypto-payment source-domain file (verified there via DLA Piper, Blakes, McCarthy Tetrault).
  • MSB revocation count (80+): Reconciled with the crypto-payment source-domain file (March 24, 2026 single-day batch of 51; ~86 across Q1 2026).
  • Tax facts (50% inclusion rate, cancelled June 2024 inclusion-rate increase, ACB cost-basis method, CARF effective 1 January 2026 / first exchange 2027, T1135 ambiguity, mining = business income / staking = income) reconciled against the refreshed digital-asset-taxation source-domain file — no change required.
  • RWA / securities facts (CSA restricted-dealer-to-investment-dealer transition, CIRO membership, NI 45-106 prospectus exemptions, OSC LaunchPad, CIRO Digital Asset Custody Framework) reconciled against the refreshed rwa-regulation source-domain file — no change required.
  • Self-reported / estimated figures flagged: CRA enforcement metrics (35 auditors, 230+ audit files, $100M collected over 3 years, 40% of platform users flagged) are CRA-reported figures carried from the source domain; setup/ongoing cost ranges (CAD 50,000-200,000 setup; CAD 80,000-300,000 annual) are advisory-firm estimates, not regulator-published fee schedules.

Targeted gap-closure pass (2026-06-06)

Operated under verification-standards.md Standard version 2026-06-04. Two register gaps worked; one closed against a fetched primary, one refined but left open.

  • CLOSED — Quebec mining energy rate (primary upgrade + correction). The prior version stated "16.603 cents/kWh for new projects using 50 kW or more; lower Rate M pricing for existing contracts." Re-verified against the Hydro-Québec 2026 Electricity Rates chart (effective 1 April 2026) (https://www.hydroquebec.com/data/documents-donnees/pdf/rates-chart.pdf — fetched as PDF and text-extracted). The current instrument is a dedicated Rate CB ("cryptographic use applied to blockchains," installed capacity ≥50 kW): authorized consumption billed at tiered rates (medium-power 6.061¢/kWh up to 210,000 kWh/month then 4.495¢/kWh; large-power 4.165¢/kWh), and energy consumption above or other than authorized consumption billed at 18.078¢/kWh (18.767¢/kWh next rate year, +3.8%). Correction: the "16.603 cents/kWh" figure does not appear in the current schedule and has been replaced; the legacy "Rate M for existing contracts" framing is superseded by Rate CB. Hydro-Québec has additionally proposed to the Régie de l'énergie an adjustment averaging ~19.5¢/kWh, expected H2 2026 subject to Régie approval, with a three-year transitional rate for existing customers (Hydro-Québec press release, fetched). Corrected in the Regulatory Direction section.
  • STILL OPEN — Stablecoin Act specific penalty/capital amounts. Re-confirmed this run that the specific penalty and reserve/capital dollar amounts are still deferred to forthcoming regulations and have NOT been published in the Canada Gazette as of 2026-06-06. The Department of Finance "Canada's Stablecoin Framework" primary page (https://www.canada.ca/en/department-finance/programs/financial-sector-policy/canadas-stablecoin-framework.html) returned HTTP 403 to automated fetch (canada.ca is a known fetch-blocker; archive.org snapshot also unreachable from this harness). A corroborating secondary was fetched (Canadian Private Lenders Association, "Canada has now passed a federal stablecoin framework," 14 April 2026) confirming detailed regulations remain to be finalized with Canada Gazette consultation expected during 2026 and in-force 2027. Per the fetch-blocker protocol this gap stays OPEN (primary-known-but-unfetchable annotation). The file wording was refined to state the amounts are NOT VERIFIED as published and to record the expected 2026 Canada Gazette consultation / 2027 in-force timeline.

Corrections Made (2026-06-04 reconciliation)

  • Stablecoin Act corrected from "proposed" to "enacted (not in force)." The prior version (modified 2026-03-20) described the framework as a "proposed Stablecoin Act (Budget 2025)" and as "not yet enacted." It was enacted via Bill C-15 (Division 45, Part 5), Royal Assent 26 March 2026; substantive provisions await a Governor-in-Council in-force order (expected 2027). Corrected in the Payment / Transfer Service Licensing section (overview, licence table, status row, stablecoin-framework note), the DeFi Protocol Licensing requirements list, and the Regulatory Direction section. Source: Parliament of Canada Bill C-15 Royal Assent; reconciled with refreshed stablecoin and crypto-payment source domains.
  • Bill C-2 / Bill C-12 conflation corrected. The prior version attributed the FINTRAC AMP increase "up to CAD 20 million" to "Bill C-2 (June 2025)." The ~40x AMP increase was in fact enacted by Bill C-12 (Royal Assent 26 March 2026). Bill C-2 (Strong Borders Act) is a separate measure (cash-acceptance restriction) that remains before Parliament and is NOT enacted. Corrected in the DeFi Protocol Licensing section. Source: reconciled with refreshed crypto-payment source domain.
  • MSB revocation figure updated from "50+ ... in 2025" to "80+ across 2025-Q1 2026," adding the 24 March 2026 single-day batch of 51. Corrected in the Payment / Transfer Service Licensing section. Source: reconciled with refreshed crypto-payment source domain.
  • "Spring 2026 expected legislation" updated to enacted. The prior version anticipated financial-crimes legislation "by Spring 2026"; this arrived as Bill C-12 (Royal Assent 26 March 2026). Updated in the Enforcement and Regulatory Direction sections.