On 4 November 2025, the Canadian federal government released its 2025 Budget called “Canada Strong” (“Budget 2025“) which signaled a major step toward regulating crypto assets in Canada. For the first time, and after much speculation that such a proposal was in the works, the federal government announced its intention to introduce legislation to govern the issuance of fiat-backed stablecoins. The proposed framework would aim to enhance consumer protection, strengthen national security safeguards and build trust in digital payment systems.

Budget 2025 was released by Prime Minister Carney’s government with the stated goal of, among other things, supporting innovation and global competitiveness. As part of an effort to support innovation in the financial sector specifically, the government indicated that it would implement new legislative frameworks to “allow responsible innovation to flourish”.

One such legislative framework related to stablecoins. Generally speaking, a “stablecoin” refers to a crypto asset that is designed to maintain a stable value over time by referencing the value of a fiat currency or any other value or right, or combination thereof. A “fiat-backed stablecoin” is a type of stablecoin that seeks to replicate the value of a single fiat currency where the issuer sets aside a reserve of assets denominated in the given fiat currency. There are many other types of stablecoins that exist beyond fiat-backed stablecoins (e.g., those backed by gold, a basket of fiat currencies, or algorithmic stablecoins), however, the proposed legislation is limited to regulating fiat-backed stablecoins only.

As set out in Budget 2025, the forthcoming stablecoin legislation will include requirements for issuers of fiat-backed stablecoins to:

  • Maintain and manage adequate asset reserves
  • Establish clear redemption policies
  • Implement robust risk management frameworks
  • Protect sensitive and personal information of Canadians

In addition, to ensure the integrity of the system, Budget 2025 indicated that the legislation will incorporate national security safeguards, with the aim of making stablecoins safe and secure for consumers and businesses to use. The forthcoming legislation is also intended to be limited to regulating stablecoin issuances by “non-prudentially regulated issuers” in Canada only.

Regarding the administration of the proposed stablecoin regime, according to Budget 2025, the Bank of Canada will administer the framework, which is expected to include a mechanism for charging fees to regulated stablecoin issuers. The 2025 Budget also contemplates amendments being made to the Retail Payment Activities Act in order to enable the regulation of payment service providers that perform payment functions using prescribed stablecoins.

The announcement of forthcoming stablecoin legislation is a welcomed development by many in the blockchain and crypto asset community. The 2025 Budget does not specify when the proposed legislation will be introduced in Parliament, leaving the timing uncertain. Canada’s approach is expected to closely mirror developments in the United States, where the GENIUS Act, which was recently passed by Congress on 18 July 2025, established a regulatory framework for fiat-backed stablecoins and enabled corporations to issue US dollar-backed stablecoins. For more information, see our GENIUS Act client alert here.

While the 2025 Budget creates a new regime to regulate stablecoins, it does not address a potential jurisdictional conflict with provincial/territorial securities laws. Generally, payment activities fall under federal oversight, while securities matters are regulated at the provincial/territorial level. To date, Canadian securities regulators have treated fiat-backed stablecoins as securities and/or derivatives (see CSA Staff Notice 21-332 and CSA Staff Notice 21-333) which will require coordination with the federal government’s proposed legislative regime to eliminate unnecessary overlap and ensure jurisdictional alignment.

Author

Michael serves as the head of the Financial Services Regulatory Practice for Canada and is a Transactional Partner in Baker McKenzie's Toronto office. His practice focuses on Canadian financial regulation and compliance for fintechs, financial institutions and financial market participants, online marketplaces, blockchain and web3 devs. Michael has assisted many global companies establish and grow their businesses in Canada. He is a co-author of Baker McKenzie's Doing Business in Canada, the Annotated Bank Act (2025-2023 editions) and the Jurisclasseur en valeurs mobilieres, a long leading treatise on securities laws in Canada.

Author

Usman Sheikh is Chair of the Blockchain, AI & Fintech Practice (Canada). He is a Partner in Baker McKenzie's Toronto office, a member of the Firm's Transactional Practice Group and is also a member of the Litigation and Government Enforcement Practice Group. He leads the Firm's blockchain team (consisting of over 150 lawyers) globally and co-leads the Firm's artificial intelligence (AI) team in North America. A highly regarded thought leader on emerging technology, Usman is often called upon globally by heads of governments, as well as key regulatory and governmental bodies, to provide insight and strategic input on legal and regulatory developments relating to emerging technologies, including FinTech, blockchain technology / digital assets, artificial intelligence (AI), Web2/Web3, quantum computing and the internet of things (IoT).

Author

Carole Turcotte is a partner in the Corporate Transactions Practice Group in Baker McKenzie's Toronto office. With over 25 years of experience as a corporate lawyer in both in-house and private practice roles, she focuses on capital markets, mergers and acquisitions, private equity and investment funds. Carole guides clients through complex domestic and multi-jurisdictional transactions, as well as regulatory challenges, helping them achieve strategic objectives.