Karsten Wenzlaff, Advisor
August 26th, 2025
October 8, 2026 | Industry Research - Call For Participation | Capital Markets, Capital Formation, Canada

On October 8, 2026, the 2026 Canadian Public Company Study, led by University of Calgary researchers Dr. L. Daniel Wilson of the Faculty of Law and Dr. J. Ari Pandes of the Haskayne School of Business, is seeking input from Canadian business leaders and capital markets professionals on why fewer companies are going public and which reforms could reverse the decline. The national survey is open until October 31, 2026.
According to University of Calgary researcher Dr. Ari Pandes' testimony before the Senate Banking Committee, the number of operating companies listed on the Toronto Stock Exchange (TSX) fell to 634 in 2025 from 1,206 in 2008, a decline of nearly 50%. The problem isn't primarily that more companies are leaving the exchange. It's that too few new companies are taking their place.
Since 2021, there have been only three TSX IPOs with primary offerings, underscoring why researchers are examining what discourages Canadian businesses from going public and which reforms could help rebuild the listing pipeline.
The researchers are seeking perspectives from two groups of experienced Canadian market participants:
The survey takes approximately 10 to 20 minutes. Participation is confidential, and the researchers state that no personally identifying information is collected. The study is partially funded by the Ontario Securities Commission (OSC) and has received University of Calgary research ethics approval (REB26-0761). Findings are intended to inform policy papers published by the OSC, C.D. Howe Institute and other outlets.
Canadian companies have more choices about where and how they raise capital. Venture capital, private equity, private credit, angels, and equity crowdfunding offer some alternatives to public listings, while secondary markets and new financial technology are expanding access private investments. The growth of tokenized pre-IPO private markets shows how investors are seeking exposure to companies before they list, although tokenized products don't necessarily provide direct share ownership or the protections and liquidity of public markets.
Canada needs to understand why companies aren't entering public markets, but also why founders and investors increasingly find private financing attractive. Listing costs, liquidity, valuations, regulatory obligations and access to growth capital all influence those decisions. The University of Calgary study can help identify which reforms would make public listings more competitive without overlooking the innovation already taking place in private markets.
Survey deadline: October 31, 2026. Eligible business leaders and capital markets professionals can participate in the Canadian Public Company Study and share the invitation with qualified colleagues.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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October 8, 2026 | NCFA Insight | Artificial Intelligence And Data, Risk Compliance And Regtech, Cybersecurity And Fraud

On October 8, 2026, the Office of the Superintendent of Financial Institutions warned that a small number of companies now dominate frontier AI models and the cloud infrastructure used by Canadian financial institutions, raising the risk of shared technology failures across the financial system. If one critical provider suffers an outage, cyber incident or operating failure, several financial institutions could be affected at the same time. OSFI also says institutions may struggle to maintain a clear view of AI use, vulnerabilities and controls at critical technology providers as adoption expands.
Canadian financial firms are advancing on AI swiftly. The Bank of Canada's 2026 Financial System Survey found that nearly all 54 respondents use AI, with planned expansion into investment management, financial crime prevention, customer service and operating workflows. Respondents themselves raised concentration among a small number of AI and cloud providers and the risk of shared mistakes when firms use similar models. OSFI now says it will assess common dependencies on critical service providers and their effects across the financial system. Canada can supervise how individual firms manage vendors, but it also needs to know when several institutions ultimately depend on the same model, cloud, API or software supplier.
OSFI hasn't introduced new AI rules. Its April frontier AI bulletin already warned that advanced models can find and chain software vulnerabilities at machine speed. Its July guidance on generative and agentic AI went further, including controls around agent identity, permissions, approvals and auditability. Those risks become more consequential as financial AI agents gain more authority inside regulated systems. The October update raises these concerns inside OSFI's formal risk outlook and puts more weight on what happens when the same suppliers support multiple institutions.
| Issue | Already known | What changed October 8 | Why it matters |
|---|---|---|---|
| AI cyber capability | OSFI had already warned that frontier models can speed up vulnerability discovery and attacks. | Frontier AI now receives focused treatment in OSFI's formal risk outlook. | AI moves closer to regular prudential supervision rather than remaining a specialist technology issue. |
| Shared providers | Existing guidance already covered third party concentration and AI dependencies. | Directly links concentrated frontier model and cloud providers with disruptions that can affect several institutions. | A supplier failure can become a financial system problem rather than stay inside one firm. |
| Foreign technology dependence | Third party and operating risk rules already covered outside technology providers. | OSFI now highlights growing dependence on technology services outside Canada. | Foreign policy, technology restrictions or geopolitical events can affect access to services Canadian firms rely on. |
| Common financial system exposure | The Bank of Canada and international regulators had already raised concentration concerns. | OSFI says it will assess common dependencies on critical service providers and their wider effects. | Regulators need to understand connections across firms, not only risk inside each institution. |
| AI adoption | Financial institutions were already expanding AI use. | Warns that moving too slowly can also weaken competitiveness and resilience. | Risk management cannot simply mean slowing AI deployment. |
OSFI is asking institutions to go faster and become more careful at the same time. Frontier AI can improve productivity, cyber defence and vulnerability detection, but governance, testing and controls have to keep pace. The Bank of Canada survey shows how quickly that tension is becoming operational. Nearly all respondents already use AI, 58% report difficulty integrating it into existing infrastructure and workflows, 56% cite talent constraints, and many expect to expand use over the next two years.
A bank may know which technology company it hired without seeing every dependency underneath that supplier. A fintech might use software that calls another company's model through an API while both services ultimately run on the same cloud infrastructure. Two vendors that look separate on a procurement list can still fail together. OSFI's July guidance reflects that problem by telling institutions to map internal and external AI dependencies, test failure scenarios, assess whether AI services can be moved or replaced and require suppliers to disclose whether they use AI to deliver services.
No public Canadian source currently shows which frontier models, cloud providers, APIs and supporting services are shared across regulated financial firms. That doesn't mean OSFI or the institutions have no visibility. It means the public evidence doesn't show a complete view across the system, while OSFI itself says firms may find it difficult to understand AI use and controls at critical third parties. The Financial Stability Board reached a similar conclusion internationally. Its AI monitoring framework focuses specifically on third party dependencies, provider concentration and the data gaps that make those risks harder to track.
The Bank of England's July Financial Stability Report says frontier AI could increase the risk of several firms or technology suppliers being disrupted at once and is being incorporated into financial sector cyber and operating tests. Its scenarios consider simultaneous disruption across firms, common technology supply chains and whether suppliers could support all affected clients at the same time. Canada has identified many of the same risks, but OSFI's October update shows that mapping and assessing common dependencies is still part of the work ahead.
Financial institutions need better ways to see which models, clouds, APIs, datasets and agents support critical workflows, where suppliers overlap and whether a service can actually be replaced during an outage. They will also need clear records showing which AI system acted, what access it had, which data it used and who approved important actions. AI agents inside payment flows already make identity, permissions, approval limits and audit trails practical operating requirements rather than abstract governance concerns.
The commercial regtech opportunity is beyond generic AI compliance software. Banks, insurers and fintechs may need live dependency maps, supplier overlap monitoring, model switching tools, agent access controls, failure testing and records that can be reviewed by boards and regulators. The recent Agentic Regulator projects show builders already working on agent identity, auditability, market monitoring and automated supervisory tools. Smaller institutions may need these tools most because they depend more heavily on outside AI providers and have less capacity to build comparable controls themselves.
Simply adding more vendors won't solve the problem if those vendors rely on the same models or cloud infrastructure underneath. Better visibility, tested alternatives and clear permission controls may be more important than the number of contracts an institution signs. As AI moves closer to financial decisions, companies that can safely connect data, models and automated actions will gain an operating advantage. The tools that make those connections visible and controllable may become just as important as the models themselves.
OSFI's October warning is really about the infrastructure underneath financial AI. Canadian institutions are adopting more capable models while relying on a technology supply chain that is concentrated, layered and often outside Canada. The next supervisory challenge is knowing when many firms depend on the same underlying technology before an outage, cyber attack or model failure reveals the connection. That also creates a clear opening for Canadian fintech and RegTech companies that can map AI dependencies, test alternatives, control autonomous agents and produce reliable records of what those systems do.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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October 7, 2026 | NCFA Market Activity | Wealthtech, Private Markets, Institutional Capital, Canada

On October 5, 2026, the Financial Times reported that La Caisse tightened its control over FNZ, a global wealth technology platform serving banks, wealth managers and investment firms, after another management change. La Caisse, the Quebec based global investment group formerly known as CDPQ, is FNZ's largest investor. FNZ appointed Stephen Welch Executive Group Chair and interim CEO in September after Blythe Masters left the chief executive role.
La Caisse has backed FNZ since 2018. CPP Investments, which manages the Canada Pension Plan Fund, committed US$1.1 billion in 2022 when FNZ was valued above US$20 billion. Since August 2024, FNZ has raised another US$2.6 billion from existing shareholders while restructuring operations, refinancing debt and changing senior leadership.
Scale isn't FNZ's problem. The company reports US$2.5 trillion of assets on platform and more than 30 million end customers. Its technology supports hundreds of financial institutions across account administration, investment operations, transaction processing and client servicing. The issue is profitability. FNZ now has to show that its scale can generate enough cash to support the business without repeated shareholder funding.
CPP Investments and Motive Partners committed US$1.4 billion to FNZ in February 2022, valuing the company at more than US$20 billion. CPP Investments supplied US$1.1 billion. FNZ then administered more than US$1.5 trillion for over 20 million customers. Four years earlier, La Caisse, then CDPQ, and Generation Investment Management acquired existing FNZ stakes in a transaction valuing the company at £1.65 billion.
FNZ has required substantial additional capital since the 2022 financing. Existing shareholders committed US$1 billion in August 2024, US$500 million in April 2025, US$650 million in November 2025 and US$450 million on September 1, 2026. FNZ also refinanced US$2.1 billion of debt in late 2024.
None of those financings establishes a lower current valuation. Private financings can alter who receives value through preference shares, warrants and other contractual rights without producing a new market price for every existing share.
Employee shareholders are challenging part of that capital structure in New Zealand, where FNZ was founded. Their US$4.6 billion claim alleges that preference shares and warrants issued during the 2024 and 2025 financings unfairly diluted employee holdings and transferred value toward institutional shareholders. FNZ says the claim is entirely without merit and that its directors acted in the company's best interests. The allegations haven't been proven.
The dispute highlights why private market valuation transparency matters once financing structures become more complicated. A financing price shows what an investor paid for a particular security at a particular time. It does not automatically tell an employee, founder or earlier investor what their position is worth after subsequent rounds add new rights and preferences.
FNZ's board currently includes three La Caisse representatives: Denis A. Turcotte, Jean Étienne Leroux and Justin Shaw. Motive Partners and Generation Investment Management also hold board seats. FNZ says Stephen Welch's appointment is intended to improve client delivery and support long term profitable growth. The Financial Times reported that investor frustration had increased, Blythe Masters was asked to step down and La Caisse became more involved in the turnaround. La Caisse has not publicly confirmed those details.
FNZ remains deeply embedded in its clients' operations. Its technology supports wealth administration, transaction processing and client servicing. Replacing it can involve long implementations, data migration, regulatory work and operational risk. FirstCape selected FNZ in 2025 to consolidate the JBWere New Zealand wealth platform and custody operation, then expanded the relationship in 2026. Several FNZ clients also joined the company's November 2025 financing.
That customer base gives shareholders a reason to keep repairing the business. It does not fix the financial performance.
The Financial Times reported an approximately US$1.4 billion pretax loss for 2025. Customization costs, acquisitions and operating expenses contributed to the loss. FNZ has sold non core businesses, cut costs and focused more closely on wealth technology for large financial institutions. FNZ UK also completed its FCA Section 166 review in 2025 after improving governance, delivery, risk management and operating controls. FNZ is reportedly targeting positive cash flow in late 2027. Until then, it still has to prove that its large customer base and infrastructure can generate enough cash to support the business without more shareholder funding.
La Caisse and CPP Investments invested at different stages, but both now have substantial capital tied to FNZ's recovery. That gives them more than a financial interest. They also have to make decisions about funding, board oversight, management and restructuring when results fall short. FNZ is too large and too international for this to be reduced to whether Canadian pension money should have stayed in Canada. The issue is whether Canadian institutional investors can manage difficult global technology investments after the original growth case weakens.
Canadian fintech capital concentration is putting more money behind fewer companies with stronger evidence of scale and execution. Larger investments can produce larger gains, but they also make operating mistakes more expensive. Wealthsimple's institutional financing shows the growth side of that model. FNZ shows what happens when investors are already committed and the business still needs fixing.
For fintech founders and operators, FNZ is a reminder that scale, customer dependence and high private valuations do not remove the need for sound economics. Complex enterprise delivery, repeated customization and acquisition growth can create costs that are difficult to unwind later. Once outside investors have committed large amounts of capital, weak financial performance can also bring more board oversight, management changes and tighter control over strategy.
FNZ shows what private capital ownership looks like after the easy financing story ends. La Caisse and FNZ's other shareholders have already supplied billions of dollars of additional capital. They are now relying on board influence, management changes, asset sales, cost controls and a narrower operating focus to improve the economics of a platform used by millions of investors.
Information notice: This article is for informational purposes only and does not constitute investment, legal or financial advice. Allegations in the FNZ employee shareholder litigation remain unresolved and have not been proven.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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October 7, 2026 | NCFA Path to Acquisition | Artificial Intelligence And Data, Canadian Fintech, Market Activity

Zeta Global agreed to acquire Senso on October 5, 2026, bringing inside the company technology that already helps power Zeta's Generative Engine Optimization offering. Toronto based Senso has moved far from its original fintech product, which used data and machine learning to predict when banking customers might switch products.
Zeta says Saroop Bharwani and the Senso team will join the company and Senso's technology will move in house. The purchase price and expected closing date were not disclosed. The more useful story is how an eight year old Canadian startup moved from financial institution intelligence into AI discovery infrastructure that a larger public company already relies on.
Senso doesn't build its own foundation model. Its current technology works between enterprise information and AI systems such as ChatGPT, Gemini, Claude and Google AI Overviews. It helps companies see what those systems say about them, which sources are being used and where important information is missing or inaccurate.
Senso then helps companies publish clearer, verified information that AI systems can retrieve and use, within the developing market for Generative Engine Optimization, or GEO. Traditional search optimization tries to improve where a webpage appears in search results. GEO focuses on how a business appears inside AI generated answers and which sources support those answers.
A company can't control what an independent AI model says or guarantee that publishing new information will change an answer. It can improve the quality, structure and accessibility of the information available to those systems.
Zeta already uses Senso technology in its GEO offering. The acquisition therefore isn't a bet on an unfamiliar product. Zeta is choosing to own a capability it already uses, along with the engineers who built it and Senso's connections to leading AI systems.
Zeta also wants to connect that AI discovery layer with customer information in its Data Cloud. Knowing that an AI system mentioned a company is useful. Connecting that answer to an audience, customer activity and a measurable business result could be worth considerably more.
Senso's current platform helps companies monitor how AI systems describe them, identify missing or inaccurate information and publish verified context those systems can retrieve and use. Y Combinator describes Senso as infrastructure for the agentic web and currently lists a team of eight in Toronto.
Current pricing and revenue aren't public, so there isn't enough evidence to judge the scale of Senso's standalone business. The acquisition value is also undisclosed, which makes it more useful to focus on what Zeta is buying rather than infer deal size.
Zeta already uses Senso technology in its GEO offering. Bringing the technology and engineering team in house gives Zeta more control over a capability it already depends on.
Senso started with a very different customer problem. At NCFA's FFCON18 VELOCITY, SENSO.AI was one of 12 companies selected to pitch live. Its software predicted mortgage churn for financial institutions and gave retention teams more time to act before customers moved elsewhere.
Later that year, Bharwani joined Fintech Fridays Episode 14. Senso was bringing together credit, real estate, location and other data to predict when customers might switch mortgages, credit cards or other financial products.
The product expanded. By the FFCON20 Fintech Draft, Senso was positioning itself around predictive revenue intelligence for lenders, including retention, acquisition and product cross selling.
The original product is gone, but the accumulated technical value is easier to see. Financial institutions had valuable information spread across different systems and data sets. Senso tried to organize those signals so machines could use them and a business could act on the result.
Today's product does something similar in a different market. Instead of helping a bank predict a customer's next financial move, Senso organizes enterprise information so AI systems can understand a company when a customer asks a question, compares products or looks for a recommendation.
Senso's move into enterprise AI was not a straight extension of its lending business. The company entered Y Combinator's Winter 2024 batch with an AI knowledge product aimed initially at credit unions. It organized documents, conversations and company knowledge so employees and large language models could retrieve better answers.
That direction eventually widened into AI discovery and GEO. The customer problem changed, but years of working with fragmented enterprise information, regulated institutions and machine learning still had value.
The Zeta agreement may now end Senso's independent company journey. Zeta says the technology will move in house and the team will join Zeta. It hasn't disclosed whether the Senso brand or legal entity will remain after closing, what Bharwani's role will be, whether Toronto operations will continue in their current form or where Senso's intellectual property will ultimately reside.
Those unknowns are part of the story. This looks less like the purchase of a large standalone software company and more like the absorption of a capability Zeta believes belongs inside its platform.
For founders and investors, that is more useful than a simple exit headline. Senso did not spend eight years scaling one product. It changed markets, rebuilt around new technology and carried forward the parts of the company that still mattered.
Senso started by helping banks understand what a customer might do next. Zeta now wants the technology because more customer decisions are beginning inside AI systems. The original product changed several times, but the durable capability was turning difficult company information into something machines could use at the moment a customer was deciding what to do.
The Company Intelligence Snapshot follows the product changes, financing and operating decisions that brought Senso to the Zeta agreement.
Senso began in Toronto by using data and machine learning to help financial institutions predict customer behaviour. By 2018, its mortgage product was designed to identify customers at risk of switching and give retention teams time to respond.
Zeta is not entering GEO by buying an unfamiliar startup. It already uses Senso technology. The agreement brings that capability and the engineers behind it inside Zeta, potentially ending Senso's independent journey while giving its technology a much larger operating platform. For other fintech founders, the more useful lesson is about resilience and product market fit. Senso did not keep forcing its original product into the market. It changed customers, rebuilt around new technology and kept the parts of the business that still had value. The path was uneven, but the company stayed close to a real problem: turning difficult enterprise information into something machines could use. That persistence eventually became strategically valuable to a larger buyer.
Information notice: Private company information and undisclosed transaction terms may change after the stated verification date. This content is provided for informational purposes only and does not constitute investment, financial or legal advice.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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October 6, 2026 | Regulation And Policy, Banking And Credit, Financial Crime And Compliance, Cybersecurity And Operational Resilience, Digital Assets Blockchain And Tokenization, Payments And Money Movement

On August 20, 2026, Toronto Centre published the podcast episode The Landscape of Financial Supervision and Security, featuring Tom Keatinge, Founding Director of the Centre for Finance and Security at RUSI, in conversation with former Basel Committee Secretary General Bill Coen. They discussed how financial supervisors should respond when foreign interference, sanctions, cyber threats and state activity move through the same institutions and infrastructure they already supervise.
Canada has been building an answer since 2023. OSFI now assesses whether federally regulated financial institutions can protect themselves against threats to their integrity and security, including foreign interference. It has also built a national security function that brings classified intelligence into supervisory work. What began as a legislative mandate is now part of how Canadian financial institutions are supervised.
A bank can be well capitalized and still face risk from foreign interference, state sponsored cyber activity, opaque ownership or compromised third parties. OSFI's integrity and security framework puts those threats inside its supervisory mandate.
In 2023, parliament expanded OSFI's mandate through Bill C 47. Federally regulated financial institutions became responsible for having policies and procedures to protect against threats to their integrity and security, including foreign interference. OSFI described the expanded mandate as a significant increase in the type of oversight it provides.
In 2024, OSFI finalized its Integrity and Security Guideline. Institutions were expected to assess risks involving foreign interference, undue influence, ownership, third parties, malicious activity and unauthorized access to their operations or assets.
In 2025, OSFI identified integrity and security as a major risk to Canada's financial system. Its work increasingly included state linked actors, cyber threats, geopolitical risk and intelligence sharing with federal security partners.
In 2026, The work continues as part of regular supervision. OSFI's 2026 to 2027 risk outlook continues to identify foreign interference, malicious cyber activity and threats to critical financial infrastructure. In September, OSFI appointed senior leadership with direct responsibility for integrity and national security.
National security has moved through legislation, supervisory guidance, intelligence capability, risk assessment and senior accountability. Banks should expect it to remain part of supervision, while fintechs may face many of the same expectations by extension through third party relationships with regulated financial institutions, including tighter due diligence, cyber, data, sanctions and incident reporting requirements.
Keatinge argues that traditional anti money laundering controls are better at finding known financial crime than activity backed by a hostile state. Money used to fund influence or interference may come from a legal source, move through regulated institutions and involve companies or people that appear legitimate. The problem may not be where the money came from. It may be who is directing the activity and why.
FATF has not said its framework is inadequate for political interference, but its own work shows how difficult state linked financial activity can be to detect. A June 2025 review found only 16% of assessed jurisdictions demonstrated high or substantial effectiveness in implementing targeted financial sanctions related to proliferation. The networks FATF describes often use front companies, hidden ownership, intermediaries, trade and virtual assets. FATF's proliferation financing review documents those methods.
FINTRAC's counter proliferation work covers sanctions evasion and threats to the security of Canada. Reporting entities are expected to look through ownership, control and corporate relationships when suspicious activity appears. A transaction can look ordinary while the people, companies or purpose behind it tell a different story.
Keatinge uses stablecoins to show how financial innovation can create economic and security risks at the same time. If households and businesses in a smaller economy transfer substantial savings from local bank deposits into US dollar stablecoins, local banks may lose part of the funding they use to make loans. At scale, that can become a financial stability and monetary sovereignty issue, especially when domestic savings and payments depend more heavily on assets and infrastructure controlled outside the country.
BIS research published in 2026 says stablecoins could make bank funding more expensive if people move money out of deposits. That could leave banks with less money to lend, including to small businesses. The IMF also warns that if money moves from local bank deposits into stablecoins backed by assets held abroad, less funding may remain in the domestic banking system. So far, however, the IMF says there is no clear evidence that this has caused widespread bank disintermediation.
Stablecoins also raise sanctions, cyber and financial crime concerns. FATF has identified virtual assets in proliferation financing and sanctions evasion, while state sponsored cyber actors have stolen digital assets to help fund government programs. Canada's stablecoin regulatory framework brings these risks into the wider debate over how digital money should be supervised.
Keatinge describes the financial system as a domain of geopolitical conflict. Regulators usually use different language, but sanctions, cyberattacks and financial infrastructure already play direct roles in relations between states. Governments can restrict access to financial transactions and services, state sponsored actors target financial institutions and payment networks, and financial infrastructure is treated as critical infrastructure.
In May 2026, G7 finance ministries, central banks, bank supervisors and market authorities ran a cross border exercise based on a large scale cyberattack affecting financial systems across G7 countries. They tested how authorities would respond, restore services, communicate during the crisis and coordinate across borders. The G7 exercise shows how a cyberattack on one part of the financial system can quickly affect institutions in other countries.
A serious attack on payments, banking access, market infrastructure or a major technology provider can disrupt services and weaken confidence at the same time. Firms building payment, identity, digital asset or financial infrastructure need to treat resilience as part of the product, not just an internal technology issue.
1. Foreign influence and a provincial referendum
In September 2026, Canada's Foreign Influence Transparency Commissioner said the office was aware of concerns about foreign influence activities directed at the Alberta referendum. The Commissioner reminded participants that arrangements with foreign principals intended to influence a provincial referendum can require registration. The Commissioner's statement shows how political influence can intersect with payments, intermediaries and funding relationships.
2. Crowdfunding brought permanently into financial crime controls
During the 2022 Emergencies Act response, Canada temporarily extended anti money laundering and anti terrorist financing obligations to donation crowdfunding platforms and certain payment service providers. After the emergency ended, the government made separate regulatory changes that permanently brought donation crowdfunding platforms and certain payment processors, including businesses handling fiat or virtual currency transactions into Canada's AML regime. NCFA challenged the permanent rules, arguing that the government had not published enough evidence to justify their scope and that smaller platforms would carry a disproportionate compliance burden. The episode shows how a security event can lead to lasting regulatory change for an entire fintech sector.
3. Digital assets used to preserve access to global finance
In August 2026, the US Treasury sanctioned two digital asset exchanges and a network of front companies that it said Iran used to launder billions of dollars, maintain covert access to international financial systems and support sanctioned actors. The Treasury action shows how exchanges, wallets and corporate networks can become part of sanctions enforcement even when a traditional bank is not at the centre of the transaction.
4. Payments routed through intermediaries
FINTRAC requires transactions originating from or bound for Russia to be treated as high risk and calls for additional checks on identity, source of funds or virtual currency, transaction purpose and beneficial ownership. Its sanctions guidance also describes shell companies, intermediary jurisdictions, crypto exchanges and brokers being used to obscure sanctioned activity. FINTRAC's Russia guidance shows why screening the immediate sender or destination may not reveal the real exposure.
5. Cyber theft used to fund weapons programs
FINTRAC has documented North Korea's use of cyber theft, digital assets, front companies and financial intermediaries in activity connected with weapons of mass destruction and ballistic missile programs. FINTRAC's proliferation bulletin connects cyber security, wallet intelligence, beneficial ownership and sanctions controls to the same state backed financing problem.
For fintechs, the risk may be behind the payment in who owns the company, who benefits, where the money is routed or what the transaction is meant to achieve. A security event can also bring new rules to an entire sector with little time to prepare.
Banks and credit unions may have to look beyond capital, liquidity and operational risk to ownership, foreign influence, sanctions, cyber threats and insider risk. Smaller institutions could face higher compliance costs as national security becomes more closely tied to supervision.
For fintechs and payment firms, onboarding may need to go beyond identity checks and standard AML screening. State linked counterparties, unusual ownership structures, high risk jurisdictions and cyber exposure can all matter. Faster payments and digital assets also leave less time to spot and stop suspicious activity.
RegTech firms have a clear opportunity. The challenge is to combine transaction data with beneficial ownership, sanctions, corporate networks and cyber intelligence without overwhelming compliance teams with false positives. AI, programmable finance and financial crime increasingly meet inside the same monitoring systems.
Founders and investors should expect these issues to arise earlier. They can affect product design, bank partnerships, regulatory approvals and access to capital well before a company reaches bank scale.
National security is becoming part of everyday financial supervision. The difficult challenge is spotting harmful activity when the money and transaction both look legitimate. Banks and fintechs will need to understand not just where money comes from, but who is behind it, where it is going and what it is meant to achieve.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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October 6, 2026 | Payments And Money Movement, Open Banking Open Finance And Data Sharing, Fintech And Innovation, Digital Assets, SME Finance And Business Banking, Competition And Market Structure

On October 6, 2026, Payments Canada released its 2026 payment trends report, showing how Canadians are paying as the country prepares to launch the Real-Time Rail. Canadians made 26.7 billion retail payments worth C$12.9 trillion in 2025, with cards still dominating payment volume while contactless use, online transfers and reported crypto payments continued to grow.
Canada is already a highly digital payment market before its Real-Time Rail launches. Canadians don't need convincing that digital payments are useful. The next opportunity is to make more of those payments settle in real time and carry better information with them.
That mix is important for fintech founders and payment providers. Cards dominate what consumers see, but much of the money moving through Canada's payment system travels through EFT and other account based channels. Business payments, treasury and reconciliation therefore matter at least as much as what happens at checkout.
Online transfers show how quickly account based behaviour has grown. Their volume increased 110% from 2020 to 2025, faster than any other payment method, while credit card volume rose 75% over the same period. It demonstrates that transferring money digitally between accounts is already familiar behaviour.
Contactless remains the dominant convenience story, while BNPL and crypto show where newer payment behaviours are developing.
The crypto increase stands out, particularly among younger Canadians, but it needs context. Payments Canada says users most often cited privacy or anonymity, transaction speed and lower fees. The survey doesn't capture how frequently people paid with crypto, which assets they used, whether a crypto linked card was involved or whether merchants ultimately received crypto or Canadian dollars. However it's proof of more reported payment use, not evidence that crypto has become a mainstream Canadian payment rail.
Payments Canada's consumer research found 52% of Canadians find real time payments appealing. The result comes from a separate survey of about 1,500 Canadian adults conducted through Leger's online panel in September and October 2025, rather than from transaction data. RTR adoption also doesn't require everyone to abandon cards or learn a new payment method.
Payments Canada plans to launch RTR in Q4 2026 with an initial group of direct exchange participants. Initial Interac e-Transfer clearing and settlement migration is scheduled for Q1 2027, followed by additional participants in Q2. Someone could keep sending an e-Transfer much as they do today while the clearing and settlement underneath that service moves onto RTR.
| Use Case | What Faster Settlement Could Change |
|---|---|
| Payroll and earned wages | A payroll service could make wages, bonuses or reimbursements available as soon as the payment settles |
| Refunds | Merchants could return approved funds without adding several more days of payment processing |
| Insurance payouts | Insurers could send an approved claim payment as soon as it is released |
| Supplier payments | Suppliers could receive funds as soon as payment is sent and settled, giving them better visibility over incoming cash |
| Merchant settlement | Payment services built on RTR could give businesses quicker access to proceeds from completed sales |
| Loan funding | Lenders could make approved loan proceeds available immediately after disbursement |
| Government payments | Benefits, refunds, rebates and emergency payments could reach recipients faster when government payment systems support RTR |
| Interac e-Transfer | A familiar service can move onto real time clearing and settlement without requiring customers to learn a new payment method |
Payments Canada says 37% of SMEs identify payment delays as a significant pain point. Instant settlement can't eliminate working capital needs, but it can shorten the period between sending money and knowing it has arrived. For businesses managing payroll, suppliers and daily cash positions, hours can matter even when days matter more.
RTR will use ISO 20022, allowing richer structured information to travel with a payment. That can include remittance information such as an invoice number, giving accounting and payment systems something useful to match against when the funds arrive. Payments Canada's business research says instant payments with enhanced data can make same day invoice matching possible.
With the right software, accounting systems can match payments to invoices automatically, treasury teams can see cash positions sooner and marketplaces can pay sellers faster. Payroll providers can offer quicker payouts, lenders can release approved funds sooner and payment companies can use payment data to improve reporting, fraud checks and cash flow tools.
Competition is opening at the same time. Registered payment service providers can now apply for Payments Canada membership, although membership alone does not guarantee RTR participation. The wider Payments Canada membership reform brings more fintechs and payment companies closer to national payment infrastructure, while the practical choices around RTR access and settlement still depend on technical, operational, security, fraud and settlement requirements.
Canada is also implementing Consumer-Driven Banking, which will let customers securely share financial data with approved providers. RTR does a different job by moving and settling payments in real time. Payment initiation could eventually connect the two, allowing an authorized service to use shared financial data, start a payment with the customer's permission and settle it quickly with useful payment information attached. Canada isn't at that stage yet, so payment initiation remains a future capability.
For businesses, that could mean using current account information to manage cash, send an approved supplier payment and match the payment to the right invoice with less manual work. Consumers could get more useful account based payment options without needing another standalone app. The bigger opportunity comes when financial data, payment instructions and settlement work together instead of sitting in separate systems.
Cards and tap already work well, while online transfers have more than doubled in five years. RTR doesn't need to replace them to create value. It can make familiar services settle faster and give businesses better payment data to automate more of the work around each transaction. As real time payments connect with financial data sharing, where will faster money and better data create something customers and businesses couldn't do as easily before?
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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