Karsten Wenzlaff, Advisor
August 26th, 2025
Karsten Wenzlaff is a Crowdfunding and Fintech Expert from Germany. He is Secretary-General of Digit[...]
Category Archives: Blockchain, Crypto, Digital Assets Regulations
CSA and CIRO Set Clear Rules for Finfluencers
Regulation | December 15, 2025
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Canadian Regulators Clarify How Finfluencer Activity Triggers Securities Law
On December 11, 2025, the Canadian Securities Administrators (CSA) and the Canadian Investment Regulatory Organization (CIRO) released new guidance for finfluencers, investment firms, and issuers on how securities laws apply to online investing activity (Download CSA and CIRO Staff Notice 31-369 13 page PDF). Social media now plays a real role in how Canadians make investment decisions, and regulators expect existing securities law to apply when online influence impacts behaviour. The guidance clarifies when creators must register, how disclosure must work in short-form content, what counts as advice or trading activity, and where firms and issuers remain responsible when they work with finfluencers. Keep reading to learn about the practical implications, including some use case examples covered in the report.
Why Regulators Are Tightening Expectations Now
Regulators are responding to what they see in the market today. Social media is no longer a side channel for financial education. It is where many investors first encounter investment ideas, products, and promotions, often without realizing when education turns into influence.
As NCFA previously reported, based on the CSA's 2024 Investor Index, 53% of Canadian investors now use social media as a source of investment information. Among younger investors aged 18 to 24, reliance on social platforms is even higher. Those investors face materially higher risk.
- 35% of surveyed investors report making a financial decision based on finfluencer content
- 12.2 times more likely to report being scammed on social media
- 2.3 times more likely to have experienced a significant investment loss, and
- 3.1 times less likely to work with a licensed financial advisor
The OSC also tests causation, not just correlation. In a controlled experiment involving 1,465 Canadians managing a simulated $10,000 portfolio, 38% of participants exposed to finfluencer style promotional posts purchased the promoted asset, compared with 8% in the control group. Exposure alone drives different investment choices, even without personalized advice.
Canadian securities regulators examined 87 finfluencers and 9 issuers and repeatedly found undisclosed compensation, promotional framing that functions as recommendations, and content drifting into advising or trading activity without registration.
The CSA and CIRO aren't introducing new rules. They are making it clear how existing securities law already applies when online content influences investment decisions. There's a clear message that Finfluencers should take seriously:
Labels and intent matter less than impact. What counts is how a reasonable investor experiences the content, not how the creator describes it.
When Finfluencers Need to Register
Finfluencers need to register when they provide investment advice or help facilitate securities trading for a business purpose, unless a specific exemption applies.
See: The Finfluencer Effect on Canadian Retail Investors
A business purpose doesn't require a formal firm, a full-time role, or a registered brand. Regulators look at how the activity actually operates. Repetition, promotion, compensation, solicitation, and continuity over time all matter. Paid courses, subscription communities, affiliate arrangements, and recurring sponsored content often meet this threshold.
The guidance is explicit that finfluencers cannot avoid registration by saying their content is not advice. Disclaimers do not change how regulators assess the activity.
What Counts as Advice and Trading Activity
Investment advice includes opinions about the merits of investing in a specific business or security, as well as recommendations to buy or sell. The guidance notes that even promotional language or emojis that imply opportunity can be interpreted as recommendations.
Trading activity is defined broadly. It includes not only executing trades, but any act done in furtherance of a trade. The guidance specifically points to copycat trading enablement, such as linking followers who pay a subscription fee to replicate trades in a self-directed account. These lines are crossed more often than many creators realize.
The General Advice Exemption Is Limited
Some finfluencers rely on the general advice exemption when providing broad and non-personalized commentary, however the regulator's guidance makes clear that this exemption is narrow and conditional.
If a finfluencer relies on it, they must clearly disclose any financial or other interest in the securities discussed. Financial or other interest is interpreted broadly and includes indirect incentives, compensation arrangements, and related party interests.
See: Bridging Canada’s Advice Gap with Global Insights
The exemption does not apply to trading activity. This distinction becomes critical when education is paired with transaction pathways.
What Proper Disclosure Looks Like in Practice
Disclosure needs to be clear, prominent, and specific enough for an audience to understand the security involved, the incentive, who paid it, and who received it.
The guidance is direct about what fails. Statements like “I may have a financial interest” are not enough. Disclosure also fails when it is buried at the end of a video, hidden behind extra clicks, or written in a way viewers are unlikely to notice.
A simple acid test applies. If a viewer has to look for the disclosure, it likely does not meet expectations.
Examples of Creators, Firms Crossing the Line
The example scenarios below highlight when creators drift into regulated activity without intending to. These aren't rare cases but common growth paths.
In one example, a creator starts with general investing education. That activity stays outside registration. When the creator adds buy and sell signals in a paid course, the activity becomes advising. When the creator begins answering personalized questions through comments and direct messages, charges fees, and scales tailored advice, registration becomes necessary or the activity needs to stop.
See: Lena Dunham’s SBF Film & Finance Pop Culture
In a second example, a crypto-focused creator promotes a token without compensation. When that creator later joins an airdrop program tied to promotional tasks, the activity becomes compensated promotion. Disclosure obligations arise immediately and need to stay current. Linking to trading platforms and receiving payments from followers or platforms can also push the activity into trading facilitation.
In a third example, a creator promotes issuer securities for payment but hides the sponsorship because disclosure reduces engagement. Disclosure is buried behind “show more” links. Regulators treat this as a breach and move to enforcement. Not knowing the rules does not change the outcome.
What Firms Need to Do Before Working With Finfluencers
Registered firms that work with finfluencers are expected to govern those relationships. That includes due diligence, written agreements, training, ongoing monitoring, and corrective action when content becomes misleading or non-compliant.
Order-execution-only dealers face added sensitivity. Because they cannot provide advice, regulators caution against indirectly enabling recommendations or registerable activity through referral arrangements, hosted content, outbound links, or copycat trading features.
For fintech platforms, this brings compliance into product design. Referral flows, creator landing pages, and trading enablement features all carry regulatory weight.
What Issuers Remain Responsible For
When issuers work with finfluencers, social media content counts as public disclosure. Issuers remain responsible for statements made on their behalf.
Regulators expect issuers to ensure content stays factual, balanced, consistent with filed disclosure, and clear about paid relationships. Issuers need to provide guidance and controls rather than leaving disclosure discipline to third parties.
See: The Finfluencer Effect on Canadian Retail Investors
Promotional shortcuts can surface later during diligence and capital raising.
How AI and Digital Influencers Are Treated
Securities law applies regardless of whether content is created by a human, a digital avatar, or an AI system. Anyone deploying AI to generate investment related content remains responsible for that content as if they created it themselves.
For platforms experimenting with automated education or AI powered engagement, note that technology does not reduce accountability.
Why This Matters
Finfluencer activity now sits firmly inside the regulatory perimeter. Data shows that influence impacts behaviour, and behaviour drives investment decisions. This new guidance gives founders, platforms, creators and issuers clarity. Teams that design content, monetization, referral flows, and product features with these expectations in mind can move faster with fewer surprises.
Read: New CFR Review Highlights Gaps Fintechs Must Close
Teams that treat finfluencer activity as casual marketing often discover where the line sits only after they cross it. That is the practical message regulators are sending, and it is one the market needs to take seriously now.
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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New CFR Review Highlights Gaps Fintechs Must Close
Compliance | December 11, 2025
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CSA and CIRO Guide Fintechs Where to Strengthen KYC, KYP and Suitability
On December 10 2025 the CSA and CIRO released new findings from their second national review of Client Focused Reforms based on 105 firms. The update arrives in a year marked by a CSA record year of 1,011 investor alerts and outreach that reached more than 4.5 million Canadians.
With the imminent arrival of Canada's commercialization of open banking, and the country's work on faster payments and new digital asset rules, fintechs now face a more demanding compliance environment, and firms must focus on fixing gaps to prepare for what comes next.
Two Client Focused Reform Sweeps
Client Focused Reforms arrived in two stages across 2021. Conflicts of interest rules took effect in June 2021 and enhanced rules for know your client, know your product and suitability took effect at the end of 2021.
Regulators did a first sweep in 2022 to confirm whether firms built the foundation. They looked at updated forms, processes and governance. The first sweep focused on whether firms completed the initial implementation work required by the reforms rather than on how well those changes worked in daily practice.
The second sweep tests practical use. Firms have lived with these rules for more than three years. Regulators expected complete records, strong reasoning and evidence of care in client decisions.
What Regulators Found In Fintech KYC Work
Regulators found that some digital onboarding flows move too quickly for the level of detail the rules require.
They saw cases where firms collected risk tolerance but did not collect risk capacity.
They found broad financial ranges that did not support detailed decisions.
See: CSA Review of EMD Selling Groups Exemption
They found missing updates when clients changed jobs, retired or faced major life events.
They also saw records that did not show meaningful conversations with clients.
👉 Regulators want firms to gather clear and complete financial information and to treat risk tolerance and risk capacity as separate concepts. They expect client data to guide decisions, not follow them. They expect fintechs to show that a digital experience still produces real understanding.
What Regulators Expect From Fintech Product Due Diligence
Fintechs often use a select list of products, model portfolios or automated recommendations. Regulators looked closely at these choices and found cases where product review notes were thin or unclear.
They found approvals without evidence of analysis.
They found firms relying on affiliates even though each firm must complete its own review.
👉 Regulators want product evaluations that show how a firm reviewed the structure, features, risks and costs of a product before deciding to offer it to clients. This work guides what a firm chooses to place on its platform and how it ensures the product suits the clients who may use it. They want clear records that show why a product fits the platform and how the firm reached that decision. They expect firms to understand their products in a practical way and to document that understanding with simple and direct notes.
What Regulators Look For In Fintech Suitability Decisions
Suitability is where digital advice models face the most pressure. Regulators found decisions marked as suitable with little or no explanation.
They found missing concentration checks and liquidity checks.
They found limited cost comparison even when firms offered lower cost fund series.
See: CSA Proposes $50K Harmonized Self Certified Investor Exemption
They saw suitability records that did not update after product changes or after changes to the representative responsible for the account.
👉Regulators want suitability work that explains how the firm connected the client’s information to the recommendation. They want firms to consider exposure levels, liquidity needs, cost differences and alternatives. They want reasoning that shows why a recommendation or a model portfolio fits the client.
How Fintechs Can Close These Gaps With Better Design
Fintechs can improve compliance by treating data, product analysis and suitability logic as design elements. Design and process can impact onboarding flows that gather clear information without slowing clients down.
Fintechs strengthen compliance when they update client profiles after major life events and use product files that link directly to real due diligence notes.
Clear concentration and liquidity checks inside the recommendation engine supports more reliable decisions.
See: Mycroft Raises $3.5M for Agentic AI Compliance Officer
Cost comparison helps firms show why a recommendation fits the client.
Investor education tools help clients understand their choices with more confidence.
Thoughtful use of AI can improve accuracy and consistency when firms understand which processes benefit most from automation.
Strong design choices make it easier to show good judgment and better care for clients.
Why Fintechs Need To Get Ready For What Comes Next
The new CFR review arrives as Canada prepares for major changes in the financial system. Open banking will introduce structured data sharing and clearer expectations for permission and accuracy. Payments modernization will accelerate how money moves, supported by Canada’s payments innovation push toward faster rails. Digital asset rules will mature as Canada moves forward with the first draft of the national stablecoin framework.
These developments point in the same direction. Regulators expect firms to show strong reasoning, accurate information and clear documentation of decisions. Fintechs that build these strengths now will be able to handle the coming changes with confidence instead of surprise.
See: Crypto Enters the Core of Canadian Payments
Good CFR practices support competitiveness and growth. Partners and investors look for firms that manage risk with care and clarity. Clients choose platforms they trust.
The CSA year in review reports 54 permanent bans imposed during the reporting period and 24 enforcement actions tied to crypto assets. This is why strong governance matters at a time when financial infrastructure is evolving.
Fintechs that build accurate data, consistent processes and quality supervision strengthen their position and gain credibility across the market.
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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Tokenized Infrastructure Is Changing How Markets Operate
Tokenization | December 3, 2025
Image: Freepik AI
Tokenization Building Modern Market Infrastructure Worldwide
Tokenized infrastructure now appears across everyday financial activity. Shared digital ledgers record ownership directly, and real assets move into programmable formats that speed up settlement, improve transparency and open access to private markets. Growth comes from regulated markets, global banks and high-growth regions that use tokenized systems to remove friction in payments, trading and recordkeeping.
Larry Fink and Rob Goldstein, CEO and COO of BlackRock (world’s largest asset manager) in a December 1, 2025 Economist article describe tokenization as a major upgrade to financial infrastructure:
“Ledgers haven’t been this exciting since the invention of double-entry bookkeeping.”
The New Market Rails Take Shape
Some of the largest and most established financial institutions already operate tokenized products in regulated environments. BlackRock issues a tokenized money market fund through BUIDL, which operates on chain and holds short-term U.S. dollar assets under a regulated structure see its 2024 launch announcement. JPMorgan runs ledger-based settlement and tokenized collateral through its Kinexys platform, formerly Onyx. UBS offers tokenized money market funds and structured products under Switzerland’s DLT Act. Franklin Templeton records shareholder ownership on chain and processes fund transactions through a blockchain-integrated fund model.
Swift reinforces this transition with real evidence. In 2023 it demonstrated that its messages can trigger tokenized transfers across public and private blockchains, confirming that banks can keep their existing workflows while settlement moves on chain. Chainlink extended these findings in Sept 2025, outlining a model where tokenized transfers move across ledgers under the same compliance controls institutions already trust.
The United Kingdom now moves beyond sandbox testing and supports full scale tokenization in asset management. In October 2025 the Financial Conduct Authority published a policy update, explaining how tokenisation can cut fund costs and widen access. The FCA also launched a consultation, setting out a roadmap for tokenised fund registers and direct to fund dealing. The FCA frames tokenization as a way to modernize asset management by placing fund units and ownership records on distributed ledgers while keeping regulatory safeguards intact.
See: NCFA Canada and TheBlock Partner to Build a Global Bridge for Tokenization
Perhaps, the strongest progress now emerges outside the West (think adoption, usage, and real economic integration). The 2025 Chainalysis Global Adoption Index demonstrates this change clearly. Its findings, highlighting leading adoption across Asia and Africa, show that Vietnam, the Philippines, India, Nigeria and Brazil all rank near the top because tokenized value moves faster and more affordably than legacy payment and settlement networks.
Regional hubs are also accelerating. A comparative review identifies Singapore and the UAE as top jurisdictions for tokenized real assets, noting that these markets scale quickly because regulators provide clear rules for tokenized cash, tokenized securities and digital registers. Where legacy constraints are lighter, adoption appears faster because the benefits materialize immediately in cross border flows, settlement and access to private assets.
In many Western financial centers, integration efforts are underway where regulations permit tokenized assets or tokenized cash to operate alongside legacy market plumbing. Liquidity follows the rails that deliver speed, safety and operational clarity.
Three Types Of Tokenization
Tokenization includes multiple assets and falls into three clear categories:
1. Tokenized cash puts digital forms of money on chain. This includes fully backed stablecoins, tokenized deposits and other types of tokenized bank money. Tokenized cash works as a settlement asset on digital ledgers. It supports instant transfers, moves easily across platforms and connects with tokenized securities and tokenized real world assets.
2. Tokenized securities are financial instruments such as bonds, funds, money market assets and equity interests that are issued or recorded on chain. They follow securities law and must meet rules for custody, disclosure and investor protection. Germany, Switzerland, the United Kingdom and the European Union all have frameworks that give these instruments a legally recognized place on digital registers.
3. Tokenized real world assets take off-chain assets and represent their ownership on chain. Examples include private credit, real estate, infrastructure assets, receivables, trade claims, commodities and revenue rights. The asset itself stays off chain, while the legal claim moves on chain, making ownership easier to transfer and manage.
Read: Fintechs Are Digitizing $33T in Alternative Assets
Tokenized cash strengthens settlement. Tokenized securities support modern regulated markets. Tokenized real world assets open access to large pools of private value. Together they form one connected system that links established institutions with modern digital first platforms.
Real Assets Move Into Programmable Form
Tokenized markets are expanding because real assets are now moving into these structures. In 2025 the strongest growth appears in United States Treasuries. A detailed review shows that tokenized Treasuries reached about $7.3B in 2025, an increase of more than 250% from 2024. These instruments deliver safe yield in a programmable, globally portable form that fits into digital collateral systems.
Coindesk reported on BlackRock’s USD Institutional Digital Liquidity Fund (BUIDL), driving much of this expansion. Messari later confirmed that BUIDL reached about $1.92B by April 2025, and Yahoo Finance reported that BUIDL passed $2.9B by mid 2025. By late 2025, the Economic Times noted that Binance accepted BUIDL as off exchange collateral.
These cases show tokenized assets working inside regulated markets. They move as collateral, pay interest automatically and settle quickly, and are demonstrating how programmable ownership can support large scale products.
A study by BCG and ADDX estimates that tokenized assets could reach $16T by 2030, while a McKinsey review projects a range of $1T to $4T by the same date. Even the low case would impact global capital formation.
NCFA has tracked similar patterns in its work on digital money, real-time tokenized payments, and competition where tokenized rails extend these forces into the full stack of asset classes.
Regulated Markets Build The Foundation
Tokenization only scales when regulators give it a clear place in existing financial law. Some jurisdictions now recognize digital ledger records as valid securities registers and allow tokenized bonds, funds or equity to operate inside their capital market systems. Others focus on tokenized cash and stable, regulated settlement assets that let digital transactions clear instantly. A few support both sides, combining securities rules with prudential oversight for tokenized money.
See: SEC Exploring Ethereum Standard for Tokenized Securities
The table below reflects these differences. It separates regimes that permit tokenized securities from regimes that regulate tokenized cash, and highlights markets that support both layers. Together these components form the legal base for tokenized assets across cash, securities and real-world assets (RWA).
| Jurisdiction | Framework | What It Allows | Role In Tokenization |
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| European Union | DLT Pilot Regime for tokenized securities MiCA rules governing tokenized cash |
Permission to issue, trade and settle financial instruments on DLT. MiCA governs crypto assets and fully backed stablecoins as tokenized cash. | Combines legal clarity for tokenized securities with rules for tokenized cash so markets can test full stack tokenization. |
| Germany | eWpG electronic securities law for DLT-based securities BaFin regulation for crypto-securities registers and trading infrastructure |
Civil law recognition for securities issued and recorded on electronic or DLT registers; legal foundation for tokenized bonds, fund units and digital securities; regulated register-keeping and custody. | Provides a comprehensive legal and regulatory framework for digital securities in Germany’s capital markets, enabling institutional issuance, trading and custody under DLT infrastructure. |
| Switzerland | Swiss DLT Act enabling ledger-based securities FINMA regulation for DLT trading venues and digital-asset infrastructure |
Legal framework for issuance, transfer and trading of DLT Securities (shares, bonds, structured products); authorized DLT trading venues under financial-market legislation; statutory recognition of ledger-based securities as book entry instruments. | Provides robust, tech neutral statutory clarity for institutional tokenized securities, regulated trading venues and digital asset infrastructure, making Switzerland a leading global hub for blockchain-based capital markets. |
| United Kingdom | Digital Securities Sandbox for tokenized securities FCA 2025 tokenisation policy for funds and asset management FCA CP25/28 roadmap for tokenised fund registers and direct to fund dealing |
Regulated issuance, trading and settlement of tokenized securities, plus a parallel program for tokenized funds, tokenized registers and modern fund dealing models. | Builds tokenization across securities markets and asset management, making the UK one of the first jurisdictions to support fund tokenization at scale. |
| UAE / Abu Dhabi (ADGM) | ADGM DLT Foundations framework ADGM Digital Assets regulation for tokenized securities & virtual assets FSRA amendments 2025 updating digital asset rules 2025 proposal for fiat-referenced token framework |
Legal basis for DLT entities, exchange of digital securities, token issuance, custody and trading under Digital Asset regulation; updated rules for virtual asset firms and a proposed framework for fiat referenced tokens. | Offers one of MENA’s most comprehensive tokenization regimes: supports security-token issuance and custody today, and paves the way for regulated stablecoins or fiat-referenced tokens, enabling full-stack tokenized markets. |
| Hong Kong SAR | Stablecoin Issuance Ordinance for tokenized cash SFC 2023 circulars for tokenised securities and authorised investment products HKMA-Government first tokenised green bond issuance (2023) |
Regulated fiat-backed stablecoins, tokenized securities offerings under SFC rules, tokenized funds and government issued tokenized bonds under HKMA structures. | Combines tokenized cash, tokenized securities and real-world-asset tokenization under a live legal and regulatory regime, including sovereign bond issuance on chain and SFC supervized fund / securities token structures. |
| Singapore | MAS stablecoin framework governing tokenized cash MAS Project Guardian initiative expanding asset tokenization |
Regulation for fully-backed, single currency stablecoins licensed under MAS; plus a regulated pathway for tokenized funds, bonds and other securities under Project Guardian. | Establishes tokenized cash rails and builds institutional frameworks for tokenized securities and real world assets, positioning Singapore as a key hub for digital capital markets in Asia. |
| United States | NYDFS 2022 guidance for U.S. dollar–backed stablecoins SEC 2025 public statement on tokenized securities regulation |
State-supervised stablecoin issuance (fully backed, redeemable USD stablecoins under NYDFS); tokenized securities treated under traditional federal securities law when issued. | Provides a defined path for tokenized cash via regulated stablecoins and maintains that tokenized securities remain subject to full securities compliance, offering partial rails but without a unified national tokenization regime. |
Canada’s Path to Tokenized Markets
Canada has made early strides toward regulating digital assets but the essential foundations for tokenized markets are still incomplete. The first draft of Canada's Stablecoin Act arrived in November 2025 via PM Carney's Budget 2025 along with Open Banking and payment modernization advancements. The Stablecoin proposal sets reserve, custody and redemption requirements for issuers and would place activity under federal oversight. It is only a draft, but it is the clearest signal that regulated tokenized cash will eventually have a place in the financial system.
Canada is also upgrading its payments infrastructure. NCFA's recent coverage of Canada’s payments innovation work, details progress on the Real-Time Rail, modernized oversight and stronger support for digital payments. The Real-Time Rail is not yet live and is expected after 2026. Until it launches, Canadian markets continue to operate on batch-based systems that limit the speed and precision needed for modern settlement, including tokenized transactions.
See: Market Forces Pressuring Fintech Plans For 2026
Canada still needs to complete several steps before tokenized markets can operate across the financial system. These include finalizing the stablecoin legislation, recognizing digital ledger registers as legally authoritative records for securities and delivering real-time settlement that works across institutions. A secure digital identity standard that functions across ledgers would also help investors and regulated firms meet KYC and AML requirements without slowing transactions.
Canada has the institutions and regulatory credibility to play a meaningful role in tokenized finance. To get there, the country must successfully and expeditiously execute its early policy work into a complete and operational model that supports lawful issuance, settlement and use of digital assets.
Why This Moment Matters And Where It Leads
Tokenization is here. Real products, regulated structures and live institutional use show how digital ledgers can cut out delays, reduce operating drag and open access to assets that rarely moved with this level of precision. When tokenized cash, tokenized securities and tokenized real-world assets run on the same digital foundation, the market gains faster settlement, clearer ownership and a simpler path for new products to reach investors. Numerous of countries are setting benchmarks with legal clarity, real time payments, and digital ledger recognition. Canada has the institutional strength to be in that group but only if it finishes the work already underway. Those that act early will define how capital moves, how assets are built and who leads the next era of financial markets.
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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Newfoundland Utility Ruling And Crypto Mining In Canada
Crypto Mining | Dec 1, 2025
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Competing Demands Within Canada’s Clean Power Strategy
On November 28 2025, the Financial Post reported that the Newfoundland and Labrador Court of Appeal issued a ruling involving Blockchain Labrador Corporation (BLC) that confirmed NL Hydro can limit firm electricity service for new crypto mining operations.
BLC originally applied for 20 megawatts of guaranteed power service for a site in Wabush but NL Hydro declined to commit to that level because it needed to protect capacity for industrial, household and export priorities. Instead, NL Hydro will supply 7.75 megawatts to the company on an interim basis.
The ruling outcome confirms that NL Hydro has set boundaries on clean electricity when new digital workloads (ie. crypto mining, AI processing) add pressure to a constrained system.
National Mining Footprint In Perspective
Canada was once a notable player in global Bitcoin mining with national activity reaching close to 10% of global hashrate in 2021 but it's participation has since declined. Hashrate Index estimated that Canada held about 4% to 5% of global hashrate in their 2023 Canadian mining review, and then in a recent Q4 2025 global hashrate heatmap update benchmarked the country near 2.9%.
Canada's reduced footprint reflects a sector now concentrated in a few established companies. This smaller group of operators (see below and note, not exhaustive) also gives provinces more room to manage clean electricity across many competing needs.
See: DMG Blockchain Plans Oregon Site for AI and Mining
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- Hut 8 operates sites in southern Alberta and North Bay and previously expanded its access to electricity resources through the Medicine Hat power agreement, while continuing to build new compute and data capacity through its Vega facility expansion
- Bitfarms continues to run hydro powered installations in Quebec, as noted in the Canadian mining assessment, along with additional development in Latin America
- HIVE and DMG maintain Canadian infrastructure while building new facilities in other regions, including DMG’s plans for Oregon expansion.
Provincial Decisions On Clean Power
Several provinces with hydro based systems have taken steps to manage electricity access for mining and other high demand digital activities.
British Columbia's clean electricity announcement enabled restrictions on new mining connections. The province later confirmed a permanent limit in the 2025 energy release, and the Court of Appeal supported provincial authority to set these boundaries in the Conifex ruling summary.
Manitoba adopted a pause on new mining activity when the utility raised concerns about the scale of new load requests. The province issued this direction in the 2022 guidance on electricity connections and extended the pause through 2026 in the 2024 directive on cryptocurrency operations.
New Brunswick took a more restrictive position. The provincial Electricity Act prevents a distribution utility from extending electricity to a new crypto mining business, which appears in the current consolidation of the Act and adopted through Bill 10.
See: Corporate Crypto Treasuries Cross $137B as DATCos Multiply
Quebec continues to serve existing projects but limits new load and uses a dedicated rate class for this sector. A review commissioned by Hydro Québec found that mining produces fewer jobs for each megawatt consumed compared to data centres and industrial users, which encouraged ongoing limits.
Alberta remains an outlier, operating a deregulated, competitive market for electricity that allows mining companies and compute operators to negotiate directly for supply, supported by broader generation options.
Global Evidence On Mining Electricity Use
Global research from the Cambridge Centre for Alternative Finance (CCAF) offers insight into energy use for digital mining. Cambridge estimates that Bitcoin mining draws about one hundred thirty eight terawatt hours of electricity per year, as described in CCAF's update on sustainable energy use and detailed further in a Cambridge digital mining report.
The research shows that more than half of global mining electricity comes from sustainable sources such as hydropower, wind and nuclear.
Low cost clean electricity attracts miners, data centres, industrial electrification and long term export contracts. Provinces build policies that protect available capacity for the users that advance their long term economic priorities.
Why This Matters
Crypto mining can contribute value when it aligns with provincial priorities but utilities now apply stronger criteria when making decisions about supplying consistent clean energy.
Read: SEC Confirms Crypto PoW Mining is Not a Security
The ruling involving Blockchain Labrador Corporation is an example of how a province evaluates new digital load against industrial development, household reliability and export duties. Informative for any Canadian fintech leaders following the developments in digital finance, compute infrastructure and national (global) ambitions for clean energy growth.
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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Australia Launches 2025 Digital Asset Framework
Digital Asset Regulation | Nov 27, 2025
Image: Australian crypto adoption 2019 2025 (Independent Reserve chart)
A Principles and Risk-based Digital Asset Framework Enters Australia’s Financial System
On November 26 2025, the Australian government led by Treasurer Jim Chalmers and Minister for Financial Services Daniel Mulino introduced the Corporations Amendment (Digital Assets Framework) Bill 2025 by official announcement New Digital Asset Laws to Unlock Innovation and Safeguard Investment.
See: Deloitte Australia’s AI Error Shakes Consulting Trust
The bill creates a clear digital asset framework that covers custody, settlement and platform operations, and it aims to raise investor protection while supporting stronger confidence across Australia’s quickly growing digital asset market. The government positions the framework as a foundation for long term innovation, including tokenization of real world assets, replacing years of uncertainty with defined expectations for operators and institutions.
Digital Assets Background In Australia
Australia has a large and active digital asset community with significant adoption, consistent user growth and a broad set of service providers, which explains the need for a clear regulatory framework. Australia also has several large crypto exchange platform operators serving mainstream users including global giants like Binance, Kraken and Coinbase to name a few.
Survey data and analysis of Australian crypto ownership in early 2025 shows that 32.5% of Australians have owned digital assets, and 70% of those investors hold Bitcoin. More than half of these investors report a profit on their activity.
Engagement continues to rise among older Australians (see chart above). Digital asset ownership among Australians over 65 reached 8.2% in 2025, up from 2% in 2019, read 'baby boomers and retirees invest in crypto'.
New Categories For Digital Asset Services
The bill creates two new financial product categories inside the Corporations Act. (1) A digital asset platform is a facility where an operator holds or controls digital tokens for clients, and (2) a tokenized custody platform is a facility where an operator holds a real world asset and links each asset to a single redeemable token.
These categories require an Australian Financial Services Licence and give operators a clear legal structure for activities that involve possession, safekeeping or management of client tokens and tokenised assets.
Principles-Based Standards For Custody And Settlement
The bill uses a principles-based approach by setting the main definitions and outcomes in the law while giving the Australian Securities and Investment Commission (ASIC), Australia’s corporate regulator, the authority to write the detailed custody and settlement standards. Parliament explains what platforms must achieve, including the need to safeguard client assets, keep accurate records, reconcile balances and manage settlement risk. ASIC then decides how platforms meet these outcomes in practice.
See: Australia Announces 10 Voluntary Responsible AI Guardrails
This approach lets ASIC update requirements as technology evolves without rewriting legislation. It keeps the focus on clear results rather than long checklists of technical steps.
Risk-Based Framework for Market Activity
The bill also uses a risk-based model that links the level of obligation to the level of exposure. Large platforms that hold significant client assets must follow stronger custody and settlement rules. Small platforms that hold less than $5,000 per customer and process less than $10 million a year qualify for a small scale exemption. This supports early pilots and lower risk use cases without placing them under the same obligations as large operators.
The Minister can also use a product intervention power when a digital asset creates clear risks for consumers or the financial system, which allows the government to place temporary limits on that product while ASIC puts longer term rules in place.
In short, the bill uses principles to define the outcomes and risk to decide how strongly those outcomes apply across the market.
Stronger Transparency For Clients
Operators must publish platform rules that act as a contract between the operator and clients. These rules must describe eligibility, settlement processes, use of external liquidity, allocation of operational risk and redemption or delivery of assets.
See: Bank of England Sets New Rules for Systemic Stablecoins
Clients receive clear information about how the service works and what risks they face, which supports informed decision making and strengthens accountability across the sector.
What Comes Next
The bill must now move through Australia’s parliamentary process, which includes further debate and committee review before a final vote. Regulators will prepare the custody standards, settlement standards and platform rule requirements once the bill becomes law. Operators will begin licensing preparation, platform rule design and compliance planning.
The next stage will also decide how the framework reaches newer parts of the market. The legislation sets the main structure, but the regulator must still fill in many operational details.
Those standards will determine how custody rules work in practice, how platforms handle execution and settlement and how services near the line between custodial and non-custodial models will operate.
There are also open questions for stablecoins, decentralized finance and some wallet services, so the practical impact of the framework will depend on how the regulator completes this work in the months ahead.
Why The Framework Matters
Digital asset custody and platform activity now follow the same regulatory expectations used across Australia's financial system. Institutions can participate with more confidence because the framework sets out clear duties for operators that hold client assets or manage tokenized activity. The government notes that digital finance innovation could generate as much as $24 billion each year in productivity and cost savings for Australia.
See: Canada Releases The First Draft Of The Stablecoin Act
The combination of principles-based standards and risk-based market obligations gives operators clear expectations as they build new tokenized real world asset projects, and supports long term innovation under rules that stay steady even as technology changes.
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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SEC Clears Fuse Token In New Crypto Decision
Crypto Regulation | Nov 25, 2025
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A New Reference Point for Behaviour-based Token Design
On November 24 2025, the US Securities and Exchange Commission (SEC) Corporate Finance Division issued a no action letter to Fuse Crypto Limited that sets the conditions under which the company can offer its ENERGY token without triggering US securities registration under Section 5 or reporting requirements under Section 12(g). This action gives the market a detailed example of how a behaviour based reward token can satisfy regulators when the program avoids speculation and ties all earning activity to user actions.
What The SEC Reviewed And The Conditions Behind Its Relief
The SEC based its position on the facts described in the request for relief letter that Fuse’s counsel submitted on November 19 2025 (13 page PDF). The filing outlines how the program works how users earn tokens and how redemption value is controlled. The SEC makes clear that any different facts or conditions could lead to a different conclusion.
Fuse’s submission describes a program that rewards users for energy related behaviour that supports distributed energy resources. Users earn tokens when they install and connect rooftop solar systems, batteries, electric vehicle chargers or similar equipment. They also earn tokens when they make this equipment available for grid supportive functions or adjust consumption to help reduce stress on local systems. These actions are measurable and tied directly to the program.
See: Coinbase Opens a New Chapter for Token Sales
The submission explains the formula Fuse uses to allocate token rewards. The formula measures user generated energy behaviour and applies a fixed structure that determines the number of tokens a user receives. This formula must remain constant. The SEC notes that it depends on this structure when evaluating whether the program’s value creation resembles investment activity.
The filing also states that redemption value is capped. Users may redeem tokens only for goods or services the program makes available at the time of redemption. The value cannot exceed Fuse’s profit margin and redemption depends on average market pricing. This removes speculative upside and keeps the token tied to consumption.
The submission also details that Fuse will present the program as a rewards system and not as an investment, and that all earning activity must flow from how users participate in the program. Users configure their preferences inside the app to enable token earning and select the settings that determine how their connected energy resources take part in the program. The filing states that token rewards come only from this participation and from measurable energy related behaviour, and that all value remains tied to capped redemption and consumptive use rather than to any form of investment activity.
The program does not give token holders any right to profit sharing future income ownership or governance. All value comes from user behaviour and redemption inside the program.
See: Are Your Tokens Securities? New EU Rules Say Maybe
These conditions help regulators understand that the token does not function like a security. The SEC confirms that its relief applies only to these facts and does not classify the token.
How The Program Works
The Fuse program connects token creation to real actions that support distributed energy systems. Users earn tokens directly from participation and do not buy them with investment expectation. The structure ties value to measurable behaviour and redemption uses a strict cap based on profit margin and market pricing. This design prevents investor style appreciation and aligns the token with its use as a reward.
This event gives issuers a detailed reference for designing behaviour based programs. Many token projects claim utility status but still allow value growth that resembles investment behaviour. Fuse provides an example of how limits on value, transparent formulas, and consumption use can support compliance.
The program also shows that clear documentation matters. Fuse’s submission provides detailed explanations of user actions, redemption rules, promotional commitments, and technical configuration.
Regulators rely on this specificity when evaluating whether a token program functions as a financial product. Fintech teams building similar programs can use this model to see how clear rules and measurable user actions help regulators understand how the system works.
Can This Work in Canada?
The SEC decision gives Canadian fintechs a good example of how American regulators analyze behaviour-based token programs. Canadian regulators continue to rely on the economic reality approach as set out in the CSA staff notice 46-308 on token classification published June 11 2018. While no formal newer guidance appears to have been issued publicly, issuers should monitor for any updates.
This guidance explains that labels do not determine the legal outcome. Regulators examine the purpose of a token how it enters circulation how users receive value and whether promotional language creates investment expectation.
See: Quebec Decision Challenges Canada’s Crypto Rules
The Fuse no action letter and submission model aligns with these principles. It shows how programs that tie value to specific actions and use measurable formulas can reduce regulatory risk. Canadian issuers designing clean energy mobility or infrastructure incentives can benefit from reviewing the program and understanding how to document participation value mechanics and redemption paths in a compliant manner.
Many Canadian fintechs build products that operate in both markets. The SEC decision provides a reference for how US regulators evaluate tokenized reward-based systems. Canadian teams could use the US-based Fuse decision to prepare materials that align with principles used in both countries.
What Could Still Change And Why The Relief Is Conditional
The No Action Letter applies only to the facts Fuse described in its incoming letter. If Fuse changes earning mechanics, redemption formulas, user eligibility, promotional language, or transferability rules the SEC may reach a different conclusion. The relief applies only to Section 5 and Section 12(g) and does not bind other regulators. The No Action Letter also doesn't prevent actions by other divisions inside the SEC or by other agencies such as the CFTC, FinCEN, IRS or state regulators.
Canadian regulators may also reach a different outcome if facts differ from the submission or if market behaviour creates investor style expectations. The SEC’s letter does not classify the token. It only describes the enforcement position for the facts presented.
Conclusion
The SEC's corporate finance decision on the Fuse reward program gives fintechs a detailed look at how behaviour based tokens can meet regulatory expectations when value comes from measurable user actions and redemption is tightly controlled.
See: The Role of a Crypto Wallet in Canada’s Digital Finance Future
Canadian fintechs designing cross-border token programs can use the Fuse no action event to help design programs and prepare materials that address the economic reality tests used in Canada. As more companies explore real world token models this type of clarity supports innovation and helps developers understand how to design programs that balance consumer incentives with regulatory confidence.
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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Canada Releases The First Draft Of The Stablecoin Act
Stablecoin Regulation | Nov 21, 2025
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Canada’s Draft Stablecoin Act Inside Bill C 15 Now Sets Out Concrete Rules
On November 18 2025, the federal government of Canada released its first draft of the Stablecoin Act when introducing the Budget 2025 Implementation Act through Bill C 15. The legislation appears in Division 45 of Part 5 and establishes Canada’s first national framework for stablecoins. The official text published in the Bill C 15 First Reading record explains that the Act sets duties for stablecoin issuers, outlines the role of the Bank of Canada and introduces rules for reserves, redemption and governance. The full clause-by-clause level rules appear in the Draft Stablecoin Act document, now moved to a dedicated page on the Department of Finance's website under Canada's Stablecoin Framework.
How Stablecoins Fit Into Canadian Law
The Act explains that if a company issues a stablecoin and follows this new federal law, the company is not treated like a bank for certain parts of the Bank Act, the Insurance Companies Act or the Trust and Loan Companies Act. In simple terms, if a company issues a stablecoin under this law, it is not treated as if it is taking deposits like a bank. This helps make sure that stablecoin issuers are regulated, but not in a way that turns them into banks.
See: Bank of England Sets New Rules for Systemic Stablecoins
The draft Act also says that if a company issues a stablecoin and follows this law, it is not treated as if it is dealing in securities for the specific federal rules listed in the Act.
Clear Duties for Stablecoin Issuers
The Act gives the Bank of Canada the job of keeping a public list of approved stablecoin issuers. An issuer must not give false or misleading information to the public.
The Act also places limits on what issuers are allowed to do. An issuer cannot use regulated words or symbols in a way that breaks future rules. An issuer cannot pay interest or any form of yield to stablecoin holders. This means stablecoins covered by this Act cannot look or act like investment products.
The Act also says an issuer cannot offer a stablecoin if it is treated as official money anywhere in the world. The issuer cannot offer a stablecoin if it is viewed as a bank deposit, if it is insured by a government deposit insurance program or if it is guaranteed by a government.
Reserves, Safety and How Customer Money Is Protected
The Act has strong rules for how issuers must hold reserves. An issuer must hold enough assets to match the full value of all stablecoins in circulation. These assets can only be used to redeem stablecoins. They cannot be used for anything else.
The reserve must consist of the same currency the stablecoin is tied to or high quality liquid assets in that currency. Only the Bank of Canada or future regulations can approve other reserve assets.
See: Quantum Safe Stablecoins Meet Real Time Finance Needs
The Act protects these reserves from being pledged, used as collateral, or borrowed against. The issuer cannot let anyone else have a claim on them.
The issuer must keep reserve assets with qualified custodians. The custodian must hold these assets separately from their own. The assets must not be available to satisfy the debts of the custodian or the issuer. They exist only to support redemptions. This helps keep customer value safe even if something goes wrong with the issuer or the custodian.
Redemption Rights for Stablecoin Holders
The Act makes clear that stablecoins must be redeemable at face value in the official currency they track. The issuer must follow this rule in line with future regulations. This protects users who want to convert stablecoins back into regular money.
Issuer Governance and Oversight
Issuers must have a governance policy that sets out who is responsible for what. This includes the responsibilities of the governing body and senior management, how accountability works, how third party service providers are managed and how conflicts of interest are handled. This pushes issuers to run stablecoin operations with clear oversight and internal controls.
Securities, Deposits and Anti Money Laundering
The Act explains where stablecoins fit into the wider regulatory world. A compliant stablecoin issuer is not considered to be dealing in securities or taking deposits for certain sections of federal prudential laws.
The Act also says that a stablecoin issuer counts as a business dealing in virtual currency under Canada’s anti-money laundering and anti-terrorist financing laws. This means the issuer must follow all federal AML and ATF rules, just like any other virtual currency business.
Outlook
The draft Act must still move through Parliament. Many details will depend on future regulations written by the Minister and guidance from the Bank of Canada. Provinces will continue to have their own rules, including securities and consumer protection laws. The restriction on interest and yield pushes stablecoins towards payment and settlement functionality rather than investment use. The reserve and custody rules help protect customers. The governance requirements ensure that issuers treat stablecoins as serious financial products with clear oversight.
See: Stablecoin Insights From FCAC’s 2025 National Survey
This draft law provides clear rules on reserves, custody, redemption and governance. It also clarifies how stablecoins fit within Canadian financial law, which helps fintechs design products, build payment systems and plan compliance with confidence. Earlier this year in July 2025, EY published a report on various approaches to global stablecoin regulation
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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