ARTICLE
25 November 2025

Ready Or Not, Federal Stablecoin Regulation Is Coming To Canada: Seven Things Issuers And Adopters Can Do Now To Prepare

GW
Gowling WLG

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Gowling WLG is an international law firm built on the belief that the best way to serve clients is to be in tune with their world, aligned with their opportunity and ambitious for their success. Our 1,400+ legal professionals and support teams apply in-depth sector expertise to understand and support our clients’ businesses.
For years, Canada's approach to digital assets has been defined by caution, a patchwork of securities guidance, provincial interpretations, and regulatory watchfulness.
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For years, Canada's approach to digital assets has been defined by caution, a patchwork of securities guidance, provincial interpretations, and regulatory watchfulness. But with Ottawa releasing its proposed Stablecoin Act this week, the landscape is poised to shift—and fast.

That shift matters. Stablecoins—digital asset tokens pegged to traditional currencies like the Canadian dollar—promise to bring the efficiency of blockchain to the reliability of cash. Their emergence is expected to streamline cross-border payments, expand financial inclusion, and even reshape how businesses and consumers move money. Yet with that promise comes scrutiny: who gets to issue them, how will reserves be managed, and what rules will ensure they're as "stable" as their name suggests.

While industry watchers unpack the details of Ottawa's new framework one thing is clear: those who wait for the final legislation to be tabled will already be behind. Businesses that begin preparing now by aligning governance, compliance, and operational systems with what's coming will be the ones ready to move when the regulatory green light turns on.

Whether you're creating, issuing, or adopting stablecoins in your business, here's what you can do today to position yourself for success in Canada's new stablecoin era.

1. Map out your regulatory exposure

The first step is understanding where your operations sit today. Are your products or digital assets already considered securities under provincial rules? Could they fall under the forthcoming Retail Payment Activities Act amendments? For adopters, how does your business currently accept payments? Are you prepared to accept stablecoins? A regulatory gap analysis, even a preliminary one, will clarify where risk lives and where opportunity begins.

2. Build relationships with regulators early

In Canada, credibility counts. Engage with the Department of Finance, Bank of Canada, and provincial securities commissions during consultations. Industry associations can amplify your input, but direct, constructive dialogue with policymakers can also build trust that lasts well beyond the consultation phase. Talk to legal counsel to ensure your plans are aligned with where the future of finance is heading.

3. Strengthen reserve management and custody practices

If stablecoins are meant to represent reliability, then reserve management is the foundation. Begin exploring partnerships with federally regulated custodians or banks to hold and attest to reserves. If your business is going to receive stablecoins, where are they going to be held? How are you going to manage a digital asset wallet? Transparency in where and how reserves are kept will become the ultimate trust metric, and custody will play a vital role.

4. Make transparency a design and compliance principle

Don't wait for regulators to demand it. Build real-time auditability and open disclosure into your token architecture. Blockchain-based reporting tools and automated attestations could evolve from "nice to have" to "non-negotiable" faster than expected. For businesses adopting stablecoins as a method of payment, ensure your compliance model accounts for the full stablecoin lifecycle, including how they are built, issued, and governed within different regulatory frameworks. Updating policies and procedures now can let you hit the ground running.

5. Create strong governance and risk frameworks

Issuers will need internal structures that mirror traditional financial institutions: independent oversight committees, conflict-of-interest policies, and formal risk management plans. Regulators may not require all of these at the start, but having them ready will make authorization smoother. Businesses that may accept stablecoins as payment will also want to update their risk frameworks and controls for the new asset class.

6. Track developments abroad

Canada won't regulate in a vacuum. The U.S. GENIUS Act and Europe's MiCA already define global precedents for stablecoin governance. Aligning with international norms now will reduce friction later, especially for issuers with global ambitions.

7. Educate your market

Even the most compliant stablecoin won't succeed without public understanding. Issuers should use this time to explain your token's structure, redemption mechanics, and safeguards in plain language. The narrative you build now will shape market trust later.

Other businesses may soon find their customers, suppliers, and everyone in between asking whether they can pay or take payment in stablecoins. Ensure you have a clear answer and framework so you can be prepared for what's next from your key partners, aligning with their adoption strategies.

The next 12 months could define the next decade of digital finance in Canada. Those who treat this interim period not as downtime, but as design time, will shape the standards others follow. In a space where trust is currency and timing is everything, early preparation isn't just prudent; it's the first competitive advantage.

Read the original article on GowlingWLG.com

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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