Bank of Canada Outlines Early Signals Across PSPs, Stablecoins, and Open Banking
At Symposium 2026, Anne Butler, Managing Director – Supervision at the Bank of Canada, shared an update on how Canada’s payments regulatory framework is being implemented, offering a view into early progress under the Retail Payment Activities Act (RPAA), as well as upcoming mandates covering stablecoins and open banking.
Her remarks reflected a system that is actively being operationalized—where registration, supervision, and new policy areas are all progressing in parallel.
A Rapidly Expanding PSP Landscape
The number of payment service providers entering the regulatory perimeter is already significant. Butler indicated that close to 1,800 entities are either registered or in the process of registration, with new applicants continuing to enter the system on a regular basis.
“There areabout 1,800 entities… either registered or in the application process… and more coming in every week.”
This growth reflects the diversity of the ecosystem. Each entity represents a different business model, which has made the registration process more detailed and time-intensive.
Understanding whether firms are performing regulated payment functions—and whether they are holding funds—requires deeper review and, in many cases, follow-up information from applicants.
Registration: Process and Practical Realities
The registration process involves multiple stages, including review by the Bank of Canada and a subsequent national security assessment by the Department of Finance.
Butler noted that the process is not immediate, given the level of scrutiny involved and the complexity of the ecosystem.
“It’s not an overnight activity because it’s actually pretty complicated.”
She emphasized that complete and accurate submissions from applicants help move files through the system more efficiently, particularly when additional clarification is required.
Supervision Begins with a Risk-Based Approach
With entities entering the register, supervision is being introduced through a risk-based model. This approach allows the Bank to determine which entities to review more closely and how frequently those reviews should occur.
“Once you’re registered, we start to conduct risk-based supervision of entities.”
Supervisory actions can range from guidance and feedback to more serious enforcement measures, particularly in situations where risks to end-user funds are identified.
At the same time, Butler made clear that the primary objective at this stage is to support industry alignment with the new framework.
“Our task under the act… is to be promoting compliance.”
Reporting and Visibility Across the System
Ongoing reporting is a key component of the supervisory framework. Annual filings, as well as incident and cyber reporting, are used to assess risk levels and inform oversight priorities.
However, Butler pointed out that incident reporting levels do not yet reflect the volume of issues known to occur across the ecosystem.
“We haven’t seen a lot of incident reporting, but we know a lot of incidents are happening.”
This gap is an area of focus as the Bank continues to build a clearer view of system-wide risks.
Clarifying the Meaning of Registration
A key distinction emphasized during the session was the nature of the RPAA framework itself.
Registration confirms that an entity is in scope of the Act and has passed initial screening requirements, including national security review. It does not indicate that the entity’s compliance systems have been fully assessed.
“This is a registration system. It’s not a licensing system.”
As a result, entities may state that they are registered, but cannot present this as formal approval from the Bank of Canada.
Stablecoins: Moving Into Scope
Beyond PSP oversight, Butler addressed the Bank’s new mandate to regulate stablecoin issuance for non-federally regulated entities.
She noted that stablecoins are increasingly being used beyond cryptocurrency exchanges, particularly in cross-border and general payment use cases.
“Stablecoin has become much more prominent… for cross-border payments and payments generally.”
The legislative framework is designed to establish clarity and trust in how these instruments operate. This includes requirements around asset backing, transparency, redemption rights, and operational resilience.
A key principle underpinning the framework is maintaining value consistency.
“Making sure that the dollar… is worth a dollar of native currency so that we can enable this as a payment method that Canadians can trust.”
The scope of regulation will extend beyond issuers to include payment service providers that use stablecoins within their services.
Open Banking: An Accreditation-Based Model
In contrast to the RPAA framework, Canada’s open banking system will follow an accreditation model.
Participation will require entities to meet defined standards before being allowed into the ecosystem, reflecting the sensitivity of financial data sharing.
Entities will be assessed based on their role, with requirements tailored accordingly, and participation will be voluntary unless designated otherwise.
This approach is intended to ensure that data sharing occurs within a controlled and secure environment.
An Evolving Framework
Across PSP registration, stablecoin oversight, and open banking, Butler’s remarks highlight a regulatory system that is still being built and refined.
Processes are developing alongside industry participation, with supervision, reporting, and new mandates all progressing in tandem.
The current phase reflects implementation in motion—where clarity is increasing, but the framework continues to evolve as the ecosystem grows.
