Canada’s Stablecoin Framework Explained: What Founders, CEOs, and Compliance Officers Must Know

What Is Canada’s Stablecoin Framework?

For years, the issuance of fiat-backed stablecoins in Canada existed in a regulatory grey zone. Platforms traded them. Users held them. Businesses built payment products around them. Yet no single federal regime governed the entities actually minting and issuing those coins. That changes with Canada’s Stablecoin Framework.

Introduced through Budget 2025 and embedded in Bill C-15 (the Budget Implementation Act, 2025), the Stablecoin Act creates Canada’s first comprehensive federal regime for the issuance of fiat-backed stablecoins by non-financial institutions. The legislation received Royal Assent, and the Department of Finance is now developing the supporting regulations, with the framework expected to come fully into force in 2027.

A fiat-backed stablecoin, for the purposes of this framework, is a digital asset designed to maintain a stable value pegged to a single fiat currency — such as the Canadian dollar or US dollar. This is distinct from algorithmic stablecoins, commodity-backed tokens, or crypto-collateralised assets, none of which fall under this regime.

The framework is built around four policy objectives: enabling innovation and competition, protecting consumers, aligning with international standards, and safeguarding financial stability. These are not aspirational — they translate directly into prescriptive obligations around registration, reserves, redemption, governance, and AML compliance.

For founders building stablecoin infrastructure, compliance officers at exchanges or payment platforms, and CEOs of MSBs or PSPs operating in the digital asset space, understanding this framework is no longer optional. It is the baseline for operating legally in Canada from 2027 onward.

What Triggered This? The Global Context

Canada did not develop its stablecoin framework in isolation. The regulatory momentum is global, driven by the recognition that stablecoins — particularly those with cross-border reach — pose systemic financial stability risks if left unregulated.

Two major international developments directly shaped Canada’s approach.

The US GENIUS Act (August 2025): The United States enacted the Guiding and Establishing National Innovation for US Stablecoins Act in August 2025, establishing a federal licensing regime for stablecoin issuers. Canada’s framework was designed with interoperability in mind, meaning future reciprocity arrangements between Canadian and US-registered issuers are a stated policy goal.

EU MiCA (fully in force, 2024): The EU’s Markets in Crypto-Assets Regulation brought e-money tokens and asset-referenced tokens under a comprehensive supervisory framework, with reserve requirements, redemption rights, and CASP licensing obligations. Canada’s framework closely mirrors MiCA’s reserve and redemption architecture.

Financial Stability Board Recommendations (2023): The FSB published its final high-level recommendations for the regulation of global stablecoin arrangements in July 2023, covering governance, reserve composition, redemption rights, cross-border cooperation, and AML/CFT obligations. Canada’s framework is explicitly designed to be consistent with these FSB recommendations. The FSB’s core principle — “same activity, same risk, same regulation” — runs through the entire Canadian framework.

This global alignment matters for your business because it signals that stablecoin regulation is hardening across all major markets simultaneously. If you operate across Canada, the EU, or the US, you are dealing with overlapping but broadly compatible regimes that share common architectural principles even where they differ in detail.

Our detailed analysis of the MiCA regulation framework and the UK regulatory changes for 2026 explore the parallel international picture in depth.

Who Does the Framework Apply To?

This is perhaps the most important threshold question, and the answer requires careful reading.

The framework applies to non-financial institution issuers of fiat-backed stablecoins who make those stablecoins available to Canadians, directly or indirectly — regardless of where the issuer is incorporated.

Breaking this down:

In scope — non-financial institution issuers:

• Fintech companies that mint and issue CAD- or USD-pegged stablecoins
• Crypto companies operating stablecoin products distributed to Canadian users
• Foreign issuers whose coins are accessible by Canadians through any channel

Out of scope — already regulated elsewhere:

• Banks, credit unions, and other federally or provincially regulated financial institutions that issue stablecoins are subject to their existing prudential frameworks — not the Stablecoin Act
• Non-fiat-backed stablecoins (algorithmic, commodity-backed, crypto-collateralised) remain under provincial securities regulator jurisdiction

Activities layer — what else is regulated: The framework governs issuance only. The use, exchange, and trading of fiat-backed stablecoins continue to be regulated by their respective frameworks:

• Trading on securities exchanges and crypto-trading platforms → provincial securities regulators
• Payment functions involving fiat-backed stablecoins → Bank of Canada under the Retail Payment Activities Act (RPAA), subject to the relevant stablecoin being prescribed in regulation

This means a business could be subject to three parallel Canadian regulatory regimes: the Stablecoin Act (for issuance), the RPAA (for payment activities), and PCMLTFA/FINTRAC (for AML). If you are unfamiliar with how these overlap, our RPAA compliance guide and MSB vs PSP licensing comparison provide the foundational context.

The framework does not distinguish between CAD-denominated and foreign-currency-denominated stablecoins. A USD-pegged stablecoin issued by a Canadian company and distributed to Canadians falls squarely within scope.

One word in the legislation deserves particular attention: “indirectly.” The framework applies to issuers who make stablecoins available to Canadians directly or indirectly. The precise meaning of “indirectly” will be defined in regulations, but it is a deliberately broad term — one that likely captures a foreign issuer whose coin is listed on a Canadian exchange or accessible through a Canadian wallet provider, even without any direct contractual relationship between that issuer and Canadian end-users. If your stablecoin reaches Canadian users through any distribution channel, do not assume the absence of a direct issuer-user relationship places you outside scope. Seek legal advice specific to your distribution model.

The Bank of Canada’s New Supervisory Role

The Bank of Canada will administer the Stablecoin Act and supervise registered stablecoin issuers. This is a deliberate institutional choice, not an accident of legislative drafting.

The Bank of Canada already supervises payment service providers under the RPAA and oversees systemically important payment systems under the Payment Clearing and Settlement Act. Stablecoin issuers fit logically within this supervisory ecosystem — they are payment-adjacent infrastructure that could, if mismanaged, pose systemic risk.

The Department of Finance Canada retains responsibility for policy and regulatory development. Draft regulations will be published in the Canada Gazette for public consultation before being finalised, which provides an important window for industry input.

For compliance officers, this supervisory structure has a practical implication: the Bank of Canada’s supervisory approach will likely be informed by the rigour it has developed through RPAA supervision. Businesses already registered as PSPs under the RPAA who also issue stablecoins will need to manage two distinct Bank of Canada relationships — one under the RPAA and one under the Stablecoin Act — with separate registration obligations and compliance reporting.

Our comprehensive guide to RPAA compliance and PSP annual reporting requirements explain what Bank of Canada supervision looks like in practice for payment institutions already in the RPAA regime.

Registration Requirements: What You Need to Provide

Non-financial institution issuers must apply for registration with the Bank of Canada before issuing fiat-backed stablecoins to Canadians. Registration is an ongoing obligation — not a one-time gate.

The application must include:

• Corporate information: Ownership structure, corporate governance, and financial health disclosures
• Technology information: Technical details about the stablecoin being issued — including the underlying blockchain infrastructure, smart contract architecture, and stabilisation mechanisms
• Compliance information: Evidence of compliance with the Stablecoin Act requirements

After registration, issuers face continuous disclosure obligations. Specifically:

• Updated information must be provided to the Bank of Canada within timeframes to be specified in regulations when significant changes occur
• Compliance reports certified by a chartered accountant and supported by a legal opinion must be submitted on an ongoing basis

That last point deserves emphasis for founders and CFOs. You will not be able to self-certify compliance. You need a qualified CA to certify the compliance report and a legal practitioner to provide a supporting opinion. This is not a regulatory nicety — it is a statutory requirement. Budget for it now.

Reserve Requirements: The 1:1 Rule

The reserve requirement is the structural heart of the framework. Issuers must maintain a reserve of assets equal to or greater in value than the total value of stablecoins they have minted and outstanding.

The reserve requirements are precise:

• 1:1 minimum: Reserve assets must equal or exceed the face value of outstanding stablecoins at all times — the FSB’s standard, which Canada has adopted, requires that the market value of reserve assets meets or exceeds the value of outstanding stablecoins, meaning nominal face value matching is insufficient if asset values have declined
• Asset quality and currency: Reserves must be held in cash or high-quality cash-like assets, denominated in the reference currency of the stablecoin — not crypto-assets, not speculative instruments, not illiquid holdings. A USD-pegged stablecoin cannot satisfy reserve requirements with CAD-denominated assets
• Qualified custodian: Reserves must be held at a qualified custodian (the specific definition of “qualified custodian” will be set in regulations)
• Segregation: Reserve assets must be segregated from the issuer’s own assets and from the custodian’s assets
• Insolvency protection: In the event of the issuer’s insolvency, reserve assets must not be accessible to general creditors — they are held exclusively for stablecoin holders

This architecture deliberately mirrors the FSB’s Recommendation 9, which requires reserves to consist of conservative, high-quality, highly liquid assets that are unencumbered and immediately convertible into fiat currency at little or no loss of value. It also closely parallels MiCA’s requirements for e-money token issuers.

For compliance officers, the segregation and insolvency-protection requirements are not simply accounting entries. They require structured legal arrangements — trust arrangements or equivalent — that need to be designed, documented, and maintained. This is compliance infrastructure, not treasury management.

Redemption Obligations: What “At Par” Actually Means

Every registered issuer must establish, publish, and follow a redemption policy. The policy must specify:

• How a stablecoin holder can redeem their coins
• The timing and manner of redemption
• Any fees that may be charged
• The role of any third parties in the redemption process

The key obligation is at-par redemption in the referenced fiat currency. If your stablecoin is pegged to the CAD, holders must be able to redeem at exactly CAD 1:1 per coin. There is no discretion to redeem at a discount.

Redemption fees, if charged, must be disclosed transparently. The FSB’s guidance — which Canada has adopted as a design principle — is explicit that fees must not be high enough to become a de facto deterrent to redemption. If your fee structure effectively prevents holders from exercising their redemption rights, that is a regulatory problem, not a business model choice.

Redemption policies must also account for stressed scenarios. What happens if an intermediary fails? The framework requires that holders retain the ability to redeem directly with the issuer even if the intermediary distributing the stablecoin becomes unavailable. This has significant implications for the contractual architecture between issuers and their distribution partners.

Governance, Risk, and Disclosure Obligations

Beyond reserves and redemption, the framework imposes a comprehensive suite of governance and operational obligations. Registered issuers must establish, publish, and follow policies on:

• Corporate governance: Clear accountability structures, board-level oversight, conflicts-of-interest management
• Risk management: Comprehensive identification and management of operational, financial, cyber, and counterparty risks
• Data security: Systems and processes for collecting, storing, and safeguarding user and operational data
• Recovery and resolution: Plans for orderly wind-down if the issuer becomes non-viable, with continuity of stablecoin holder rights

The disclosure obligations are substantial. Users must have access to meaningful information about the governance structure, the reserve composition, the stabilisation mechanism, and the redemption process. Beyond user-facing disclosures, issuers are also required to provide the Bank of Canada or the Minister of Finance with any information requested — an open-ended supervisory information power that is not limited to scheduled reporting cycles. Compliance officers should understand that the Bank of Canada’s supervisory reach is not bounded by what is specified in your compliance reports alone. The FSB’s template for reserve asset disclosure — requiring disclosure of the market value at month-end and the daily average over the most recent quarter across each eligible asset category — provides a useful benchmark for what regulators expect.

AML/ATF Obligations: The PCMLTFA Layer

The Stablecoin Act is not a standalone compliance universe. Stablecoin issuers are also subject to Canada’s anti-money laundering and anti-terrorist financing regime under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).

The nexus is clear: stablecoin issuers are classified as money services businesses (MSBs) dealing in virtual currencies under the PCMLTFA. This means that alongside the Stablecoin Act obligations, issuers must maintain:

• A fully compliant AML/ATF compliance programme under PCMLTFA s.9.6, including written policies and procedures, a designated compliance officer, risk assessment, and a training programme
• FINTRAC registration as an MSB dealing in virtual currencies
• Customer due diligence (KYC/CDD) and enhanced due diligence (EDD) for higher-risk customers
• Transaction reporting obligations: suspicious transaction reports (STRs), large cash transaction reports (LCTRs), and electronic funds transfer reports (EFTRs) where applicable
• Record-keeping obligations consistent with PCMLTFA requirements
• Compliance with the FATF Travel Rule for virtual asset transfers

This dual-layer compliance reality — Stablecoin Act obligations to the Bank of Canada, plus PCMLTFA obligations to FINTRAC — is one of the most practically challenging aspects of this framework for founders to internalise. These are not the same regulator, not the same legislation, and not the same compliance programme. They are parallel, overlapping obligations that must both be maintained and that will both be subject to examination.

Our FINTRAC AML requirements guide, KYC requirements for Canadian MSBs, and complete AML programme blueprint cover the PCMLTFA layer in full detail. The lessons from Canada’s historic $176M FINTRAC penalty illustrate what non-compliance costs.

If you need to understand how registration works as an MSB dealing in virtual currencies, our Canada MSB license guide is the starting point.

What You Cannot Do: Key Prohibitions

The Stablecoin Act establishes several categorical prohibitions that are important for founders and product teams to understand clearly.

No yield or interest: Issuers are prohibited from offering interest or yield to stablecoin holders. This is a structural prohibition, not a disclosure requirement. You cannot pay holders for holding your stablecoin, regardless of how the product is framed. This prohibition aligns directly with MiCA’s treatment of e-money tokens and reflects regulatory concern that yield-bearing stablecoins begin to functionally resemble deposits.

No deposit or legal tender misrepresentation: Issuers cannot represent that their stablecoin is legal tender, a deposit, or insured under a public deposit insurance system. This prohibits marketing language that implies CDIC protection or Bank of Canada backing.

No false or misleading information: The use of terms, expressions, logos, symbols, or illustrations specified in regulations to communicate false or misleading information about the stablecoin is prohibited. The specific restricted terms will be defined in regulation.

No algorithmic stabilisation: While not stated as an explicit prohibition in the same list, the framework’s requirement for a 1:1 reserve of high-quality liquid assets functionally excludes algorithmic stablecoins. There is no pathway to registration for a stablecoin that relies on algorithmic protocols to maintain its peg.

For product and marketing teams, these prohibitions need to be embedded into your communications review process immediately — not once the framework comes into force.

Enforcement: Penalties and National Security Powers

The Bank of Canada has enforcement authority under the Stablecoin Act. Non-compliance can be addressed through:

• Compliance agreements: Negotiated remediation plans for less severe violations
• Administrative monetary penalties (AMPs): The specific penalty amounts will be set in regulations, but the framework follows the general pattern of Canadian financial sector statutes

The Minister of Finance holds significant national security powers that go beyond ordinary enforcement. The Minister can:

• Refuse access to the registration framework for national security reasons
• Prohibit an issuer from taking any measures related to issuing stablecoins to Canadians if it serves the public interest or national security
• Impose conditions or require undertakings from issuers where necessary for national security reasons

These powers are modelled on equivalent provisions in the RPAA and the Consumer-Driven Banking Act. They give the government a broad backstop that operates independently of the Bank of Canada’s supervisory tools. For foreign issuers in particular, these national security authorities represent a meaningful market access risk — registration can be refused on national security grounds without the ordinary procedural protections that apply to AMP proceedings.

The Timeline: 2025 to 2027

Understanding the regulatory timeline is essential for planning purposes. The framework is not in force yet, but the legislative foundation is laid and the regulatory development process is underway.

Milestone	Timing
Bill C-15 (Budget Implementation Act 2025) introduced with Stablecoin Act	Budget 2025
Royal Assent received	2025
Department of Finance begins regulatory development with Bank of Canada	Early 2026
Draft regulations published in Canada Gazette for consultation	2026 (estimated)
Regulations finalised	Late 2026 / Early 2027
Stablecoin framework comes into force	2027 (expected)

The Department of Finance has indicated that regulatory development is expected to continue over 12–18 months from early 2026, meaning the framework will likely come into force in 2027.

For compliance officers, the Canada Gazette publication of draft regulations is a critical engagement window. This is the formal public consultation period where industry can submit comments on the proposed regulatory text. Engage early — the consultation window will not be long, and the rules as drafted in the Canada Gazette are often close to the final outcome.

What This Means for Different Business Types

Stablecoin Issuers (Domestic)

You face the most direct and comprehensive obligations. Registration, reserve maintenance, redemption policies, governance frameworks, CA-certified compliance reports, and parallel PCMLTFA obligations as an MSB. The compliance infrastructure you need to build is substantial. Start now.

The good news: if your compliance programme is well-designed, registration should be achievable. The framework does not appear to limit the number of registered issuers or impose market-cap thresholds that would exclude smaller players — though regulations may introduce such criteria.

Foreign Stablecoin Issuers (Distributing to Canadians)

The framework applies to you. “Making stablecoins available to Canadians, directly or indirectly” is the scope trigger, not incorporation in Canada. If your USDC-equivalent, EUR-stablecoin, or CAD-pegged coin is accessible by Canadian users through any platform or wallet, you are within scope for registration.

You will also be subject to PCMLTFA as an MSB dealing in virtual currencies if you are conducting business in Canada — a separate obligation from the Stablecoin Act registration.

Our FINTRAC 2026 MSB revocations analysis shows what happens to businesses that ignore these obligations.

Crypto Exchanges and Trading Platforms (Not Issuers)

If you are a CASP, exchange, or trading platform that lists fiat-backed stablecoins but does not issue them, the Stablecoin Act issuance obligations do not directly apply to you. However, two other regulatory layers are relevant:

• Securities regulators continue to govern the exchange and trading of stablecoins on your platform
• If you perform payment functions in a fiat-backed stablecoin, and that stablecoin is prescribed under RPAA regulation, you fall under Bank of Canada supervision for those activities

You should also consider the AML implications of listing stablecoins issued by unregistered or non-compliant issuers once the framework is in force. Our articles on VASP compliance global standards and offshore VASPs and the FATF oVASP report are directly relevant.

Payment Service Providers (PSPs) Registered Under RPAA

Your existing RPAA registration does not cover stablecoin issuance. If you intend to expand your product into stablecoin issuance — even CAD-backed stable payment instruments — you will need a separate registration under the Stablecoin Act. The Bank of Canada will supervise you under both regimes, but the obligations are distinct and cannot be merged.

For PSPs already navigating RPAA obligations, our PSP compliance guide and Bank of Canada annual reporting guidance explain the existing regime in full.

MSBs Dealing in Virtual Currencies (Not Issuers)

If your MSB business involves exchanging, transferring, or facilitating access to stablecoins but you do not issue them, the Stablecoin Act registration obligation does not apply. Your existing PCMLTFA and FINTRAC MSB obligations continue. However, your AML risk assessment should be updated to account for the regulatory status of the stablecoins you handle — listed vs. unlisted, registered vs. unregistered issuers will become a meaningful AML risk factor once the framework is in force.

Our MSB AML audit requirements and FINTRAC MSB renewal guide provide the PCMLTFA context.

How Canada’s Framework Compares to MiCA and GENIUS

Feature	Canada (Stablecoin Act)	EU (MiCA — EMT Rules)	US (GENIUS Act)
Regulator	Bank of Canada	National Competent Authorities (ECB for systemic issuers)	Federal banking agencies / state regulators
Scope	Non-FI issuers of fiat-backed stablecoins	E-money token issuers	Payment stablecoin issuers
Reserve requirement	1:1 high-quality liquid assets	1:1 segregated, denominated in reference currency	1:1 high-quality liquid assets
At-par redemption	Yes	Yes	Yes
Yield prohibition	Yes	Yes (all EMT holders)	Yes
AML integration	PCMLTFA / FINTRAC	AMLD6 / national AML regimes	Bank Secrecy Act / FinCEN
National security powers	Yes (Minister of Finance)	No equivalent provision	Limited
Interoperability goal	US and EU	Mutual recognition (developing)	International alignment stated
Expected in force	2027	2024 (fully in force)	2025

The similarities across these three frameworks are not coincidental — they all draw from the FSB’s 2023 recommendations, which Canada, the US, and the EU have each adopted as a design baseline. This convergence is good news for multi-jurisdictional operators: the compliance architecture that satisfies one framework will largely satisfy the others, with jurisdiction-specific variations.

The key divergences to watch are the national security powers (unique to Canada at this level of breadth), the CA-certified compliance report requirement (a Canadian specificity not present in MiCA or GENIUS in the same form), and the specific reserve asset composition rules that will be defined in Canadian regulation (which may differ from MiCA’s detailed asset eligibility criteria).

Action Steps for Compliance Officers and Founders

The regulatory development timeline gives you a meaningful preparation window. Here is how to use it.

Immediate (Q2 2026):

• Conduct a scoping assessment: does your current or planned product fall within the Stablecoin Act’s definition? Does your distribution reach Canadian users?
• If you are a potential issuer, engage legal counsel to assess your regulatory position and begin mapping the governance obligations
• Review your existing FINTRAC/PCMLTFA registration status — if you are not already registered as an MSB dealing in virtual currencies and you issue or plan to issue stablecoins in Canada, registration is a pre-condition
• Monitor the Canada Gazette for draft regulation publication

Short-term (Q3–Q4 2026):

• Submit comments during the Canada Gazette consultation period — your input on reserve asset definitions, qualified custodian criteria, and AMP penalty structures can meaningfully shape the final regulations
• Begin designing your compliance programme architecture: governance policies, risk management framework, data security policies, and recovery/resolution plan
• Engage a qualified CA to understand the compliance reporting requirements so you can structure your internal reporting accordingly
• Review your reserve management approach and begin building relationships with qualified custodians

Medium-term (Pre-2027):

• Build and test your redemption infrastructure — at-par redemption must be operational, not planned, when the framework comes into force
• Complete your AML programme if not already compliant with PCMLTFA, including STR procedures, KYC processes, and transaction monitoring
• Prepare your registration application for submission once the registration process opens
• Conduct a full pre-registration compliance gap assessment against the finalised regulations

ComplyFactor provides AML advisory, fractional MLRO services, AML compliance programme development, and independent AML audit services for Canadian and international fintechs navigating exactly this regulatory transition. If you are building stablecoin infrastructure and need to get your compliance foundation right, contact us.

Frequently Asked Questions

Does the Stablecoin Act apply to USDT or USDC if they are distributed to Canadians?

Yes. The framework applies to foreign issuers who make fiat-backed stablecoins available to Canadians, directly or indirectly. Tether (USDT) and Circle (USDC), as non-financial institution issuers of fiat-backed stablecoins, would very likely fall within scope. Whether they choose to seek Canadian registration, restructure their Canadian distribution, or cease offering to Canadians is a business decision — but the regulatory obligation will apply once the framework is in force in 2027. Canadian exchanges listing these coins should monitor this issue closely, as listing a stablecoin from an unregistered issuer may carry its own compliance risks.

Are algorithmic stablecoins covered?

No. The framework is limited to fiat-backed stablecoins. Algorithmic stablecoins, crypto-collateralised stablecoins, and commodity-backed tokens are not within scope. Non-fiat-backed stablecoins continue to be regulated by provincial securities regulators.

If we are already registered as a PSP under the RPAA, do we need a separate Stablecoin Act registration?

Yes. RPAA registration and Stablecoin Act registration are separate obligations administered under different legislative instruments. Your RPAA registration does not substitute for, or automatically include, registration as a stablecoin issuer.

What happens to our existing PCMLTFA/FINTRAC obligations as an MSB when the Stablecoin Act comes into force?

Nothing changes. The Stablecoin Act is additive, not substitutive. Your PCMLTFA obligations as an MSB dealing in virtual currencies remain fully in place. You will maintain both a PCMLTFA compliance programme (reporting to FINTRAC) and Stablecoin Act obligations (reporting to the Bank of Canada). Our FINTRAC 5-element AML programme framework is a useful reference for ensuring your PCMLTFA foundation is solid.

When will draft regulations be published?

The Department of Finance indicated that regulatory development is expected to continue over 12–18 months from early 2026. Draft regulations should be published in the Canada Gazette during 2026, with final regulations coming in late 2026 or early 2027. Monitor the Department of Finance Canada and Bank of Canada websites for announcements.

Can a stablecoin issuer offer staking or yield rewards to holders?

No. The framework explicitly prohibits issuers from offering interest or yield to stablecoin holders. This is a categorical prohibition, not a disclosure or structuring question. Any product that pays holders for holding the stablecoin — regardless of how it is labelled — would violate this prohibition.

What qualifies as a “qualified custodian” for reserve purposes?

The specific definition of qualified custodian will be established in regulations. Based on the framework’s alignment with MiCA and the FSB recommendations, it is reasonable to expect that qualified custodians will need to be regulated financial institutions with appropriate safeguarding capabilities, insurance, and segregation infrastructure. Crypto-native custodians without prudential regulation are unlikely to qualify under this standard.

If our stablecoin is only used within a closed ecosystem (e.g., a loyalty programme), does the framework apply?

Scope depends on whether the instrument meets the definition of a fiat-backed stablecoin and whether it is made available to Canadians. Closed-loop instruments that do not function as general-purpose payment instruments or stores of value may fall outside scope, but this requires careful legal analysis. Do not assume exclusion without confirming it.