Written By Simon Grant and Matthew Flynn
Bank of Canada Publishes List of Payment Service Providers, Begins Contacting Non-Applicants
In order to carry on business in Canada as a payment service provider (PSP) in September 2025, PSPs are required by the Retail Payment Activities Act to register with the Bank of Canada through PSP Connect on the Bank of Canada website. We discussed this new requirement in more detail in our Q3 2024 edition of Fintech in Canada.
Now that the November 1-15, 2024 initial registration window has closed, the Bank of Canada has published a searchable list of all entities that have applied to register as PSPs on its website.
The Bank of Canada will start to publish a list of successfully registered applicants beginning September 8, 2025, as well as a list of applications that were refused. In the meantime, the Bank of Canada is following up directly with companies that it believes are in scope as PSPs but have not registered.
The Bennett Jones Financial Services group can support clients navigating this complex framework.
USDC Stablecoin Issuer Circle
As highlighted in the Q3 2023 edition of Fintech in Canada, the Canadian Securities Administrators (CSA) published CSA Staff Notice 21-333 Crypto Asset Trading Platforms: Terms and Conditions for Trading Value-Referenced Crypto Assets with Clients (the "Notice") in October 2023.1 This Notice set forth the terms and conditions for issuers of stablecoins (value-referenced crypto assets) that want to offer and continue to trade their stablecoins on a Canadian crypto asset trading platform. Among other requirements, the Notice mandates issuers to file an undertaking that includes specific representations and commitments to the CSA.
On December 3, 2024, Circle Internet Financial, LLC (Circle) was the first stablecoin issuer to file an undertaking with the CSA with respect to its US dollar-referenced stablecoin (USDC).2 As the CSA imposed a filing deadline of December 31, 2024, and no other issuers of stablecoin have made an undertaking with the CSA as of the date of this article, Circle is the only issuer of stablecoins that has provided an undertaking.
1 Canadian Securities Administrators, "CSA Staff Notice 21-333 Crypto Asset Trading Platforms: Terms and Conditions for Trading Value-Referenced Crypto Assets with Clients" (October 2023) online: Canadian Securities Administrators.
2 Circle Internet Financial, LLC, "Circle-CSA Undertaking" (3 December 2024) online: Canadian Securities Administrators.
Please note that this publication presents an overview of notable legal trends and related updates. It is intended for informational purposes and not as a replacement for detailed legal advice. If you need guidance tailored to your specific circumstances, please contact one of the authors to explore how we can help you navigate your legal needs.
For permission to republish this or any other publication, contact Amrita Kochhar at kochhara@bennettjones.com.
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