- The Stablecoin Act received Royal Assent on March 26, 2026, as part of Bill C-15, with the Bank of Canada as supervisor.
- The framework is anticipated to come into force in 2027, once regulations are made.
- Whether you might issue, distribute or simply hold stablecoins, the time to take stock is before the regulations are published.
What was enacted
The Stablecoin Act was enacted through the Budget 2025 Implementation Act, No. 1 (Bill C-15), which received Royal Assent on March 26, 2026. It regulates private-sector issuers of stablecoins, defined as digital assets intended or designed to maintain a stable value relative to the value of one fiat currency. It applies to stablecoins with interprovincial or international application.
It does not apply to central banks or to closed-loop stablecoins. Federally regulated financial institutions are excluded, subject to regulatory exceptions.
Who supervises
The Bank of Canada is the primary authority for supervising issuers, monitoring the market and enforcing compliance. Issuers that are not prudentially regulated must be listed on a public registry kept by the Bank before they issue stablecoins in Canada. An application covers ownership, organization, technology and operational policies, evidence of financial condition, and statements from a lawyer and a certified accountant. The Minister of Finance can direct the Bank to refuse an application.
What issuers must do
- Hold reserve assets in the reference currency with a value at least equal to the par value of the stablecoins outstanding.
- Keep reserves segregated, unencumbered and with qualified custodians, and use them only to meet redemptions.
- Maintain a redemption policy and redeem at par.
- Report to the Bank of Canada at least monthly, including an independent accountant's statement on financial condition and reserves, and an independent lawyer's statement that reserve assets are unencumbered and properly held in custody.
- Publish governance, risk management, data security, and recovery and resolution policies.
- Not make false or misleading statements, and not pay holders interest or yield.
The Bank can impose administrative monetary penalties. Violations of the Act are not criminal offences.
Timing
The Bank of Canada's supervisory role took effect on March 26, 2026. The Department of Finance is developing regulations over the following 12 to 18 months, and the framework is anticipated to come into force in 2027. Details that depend on those regulations, including the exceptions for federally regulated financial institutions, are not yet final.
What to check now
The Act is mainly about issuers, but it changes the environment for anyone who distributes, accepts or holds stablecoins. These are the questions we would put on the agenda.
- If you might issue. Would your institution, or a planned product, fall within the definition of a stablecoin issuer, and which exclusions could apply? This needs legal advice early.
- If you distribute or integrate. How will you assess an issuer's registry status, reserve arrangements and redemption terms before you offer its stablecoin to clients or build it into a product?
- If you hold or pay in stablecoins. Does your treasury policy set criteria for eligible stablecoins, limits by issuer, and a response plan if redemption is disrupted?
- For everyone. Who is tracking the regulations as they are published, and who will act on them?
None of this needs a decision today. It does reward an early inventory of where stablecoins touch your business, so that you respond to the regulations rather than discover them.
Sources
This is a summary of published law-firm commentary as of October 2026. It is not legal advice. Read the Act and take legal advice on your own position.