Canada Proposes Mandatory Crypto Exchange Registration ...

CSA's proposal would replace 13 provincial and territorial regulatory regimes with a single crypto exchange registration framework. Foreign exchanges serving Canadian residents would need to register or exit.

What the CSA wants

The Canadian Securities Administrators published a proposed national instrument in January 2026 that would create a unified registration category for crypto asset trading platforms operating in Canada. The comment period closes March 31, 2026, with a target implementation date of Q4 2026.

Under the current system, crypto exchanges must register separately in each province where they operate. Ontario's OSC, Quebec's AMF, British Columbia's BCSC, and Alberta's ASC all maintain their own registration processes, timelines, and conditions. A platform serving customers in all ten provinces and three territories needs to navigate up to 13 regulatory relationships.

The proposal consolidates this into a single "Crypto Asset Trading Platform" (CATP) registration. Platforms would apply through their principal regulator (usually the province where their head office is located) and receive a passport to operate nationally. The CSA estimates this will cut registration timelines from 12-18 months to 4-6 months.

Foreign exchanges on notice

The proposal's most significant impact falls on foreign exchanges. Since 2022, the CSA has required foreign platforms serving Canadian residents to file pre-registration undertakings. Some did. Many didn't. Enforcement has been inconsistent.

Under the new rules, any platform accessible to Canadian residents (including through a website or app available in Canada) must either register as a CATP or implement geo-blocking for Canadian IP addresses. The CSA has specifically flagged offshore exchanges that accepted Canadian users without filing undertakings as enforcement priorities.

Binance left the Canadian market in 2023 after the OSC tightened requirements. Other large platforms, including OKX and Bybit, have operated in a gray zone. The new framework would force a clear decision: register or leave.

What registration requires

The proposed CATP registration imposes several conditions that go beyond current provincial requirements:

Segregation of client assets with Canadian custodians or qualified foreign custodians
Proof of reserves audited quarterly by a CPAB-registered auditor
Minimum insurance coverage for custodial assets (amount TBD in final rules)
Mandatory suspicious transaction reporting to FINTRAC
Restrictions on margin and leveraged trading for retail investors

The custody requirements are particularly demanding. Platforms must demonstrate that client assets are held separately from operational funds and protected in the event of insolvency. The FTX collapse clearly influenced this provision.

Will it actually simplify things?

The passport system sounds efficient on paper. In practice, Canada's securities regulatory architecture is famously fragmented. A national securities regulator has been proposed and rejected multiple times over the past two decades, most recently in 2018 when the Supreme Court upheld provincial jurisdiction.

The CSA is a coordinating body, not a unified regulator. Each provincial regulator retains enforcement authority within its jurisdiction. The passport system works for traditional securities registration, but crypto platforms have tested interregional coordination in ways that equity dealers never did.

Industry groups including the Blockchain Research Institute have cautiously supported the proposal while noting that Canada risks driving innovation to more permissive jurisdictions. The US, despite its own regulatory confusion, doesn't require state-by-state registration for crypto exchanges.

The UK's FCA has its own registration regime that Canadian regulators appear to have studied, particularly the consumer protection and custody provisions. Whether Canada can implement more smoothly than the FCA (which has rejected over 80% of crypto registration applications) remains to be seen.

Comments are due March 31, 2026. The final instrument is expected in Q3 2026.