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CSA Proposes NI 26-101 for Market Technology Integrity

October 1, 2026 | NCFA Market Activity | Capital Markets And Market Infrastructure, Cybersecurity And Fraud, Risk Compliance And Regtech, Regulation And Policy

AI Illustration of Canadian capital markets technology infrastructure illustrating cybersecurity, cloud resilience and AI oversight under CSA NI 26-101

Market Infrastructure, Technology Resilience And Future AI Rules

On October 1, 2026, the Canadian Securities Administrators proposed NI 26-101 Information Technology System Integrity, a national framework for technology systems used by marketplaces, clearing agencies, trade repositories, information processors and matching service utilities. The proposal would bring existing IT requirements into one instrument and make the rules more consistent across Canada's core capital market infrastructure. Comments close January 29, 2027.

The proposed rule is only the first phase. The CSA is also asking whether a second phase should add more explicit requirements for cybersecurity, cloud services, outsourced technology and artificial intelligence, and whether technology integrity rules should eventually reach a wider group of securities market participants.

NI 26-101 Consolidates Core Market Technology Rules

Canadian trading, clearing, reporting and market data systems already operate under technology requirements spread across several securities rules. NI 26-101 would consolidate those obligations into one national instrument and use more consistent language across the organizations that run critical market infrastructure.

See: AI Agents Probe Library and Archives Canada

The organizations in scope perform different jobs, but all depend on technology that can handle trading volume, stay available and recover when systems fail.

  • Marketplaces operate exchanges and alternative trading systems such as the TSX and other regulated trading venues
  • Clearing agencies support post trade clearing and settlement infrastructure
  • Trade repositories collect derivatives transaction data for regulators, including designated repositories such as DTCC Data Repository
  • Information processors consolidate and distribute market data, such as the TMX Information Processor
  • Matching service utilities electronically match institutional trades before settlement

Canada is also adding new trading infrastructure. CIX Trading recently launched Canada's first new equity ATS in more than a decade, adding another venue to the systems brokers use for order routing, execution and market data. New entrants can increase competition, but every additional connection also raises the value of reliable infrastructure and clear operating standards.

The CSA describes Phase 1 primarily as consolidation and harmonization. It doesn't turn every technology risk discussed in the consultation into a new rule, and it should not be read as a new AI or cybersecurity regime.

Phase 2 Could Add Cyber, Cloud And AI Requirements

The Phase 2 consultation questions go further. The CSA is asking whether market infrastructure firms should face clearer cybersecurity requirements. That could include ongoing system monitoring, security testing, regular checks for weaknesses and exercises to see how well firms can recover from a cyber incident. Regulators are also asking whether outside experts should test these systems and whether serious findings should be reported.

The questions build on work the CSA is already doing elsewhere. A recent review of cybersecurity controls at registered firms looked at policies, risk assessments, oversight of outside technology providers and incident response. NI 26-101 starts with market infrastructure, but the consultation asks whether similar requirements should eventually reach other securities firms.

The CSA is also looking at cloud services and other outsourced technology. It wants feedback on where data is stored, how much firms rely on the same large providers, how risks are managed when suppliers depend on other suppliers, and how firms should oversee outside AI providers.

See: AI Agents Expose Weak Links in Financial Authorization

Artificial intelligence is not directly regulated by the proposed NI 26-101. For Phase 2, the CSA is asking whether firms should have specific AI risk controls, minimum oversight, clearer records of how AI is used and reporting when AI supports a critical system or service. Quantum computing, blockchain and tokenization are also listed as technologies that may need clearer treatment.

The future scope could extend beyond exchanges and clearing infrastructure. The CSA is asking whether registrant firms, investment fund issuers, benchmark administrators, regulation services providers and self regulatory authorities should also come under a wider technology integrity framework.

Compliance Costs Could Affect New Entrants

Stronger testing, cyber controls and oversight of outside technology providers would add costs for regulated firms. Large exchanges and clearing organizations already support extensive technology programs, while smaller venues and new infrastructure providers have fewer resources to absorb recurring testing, assurance and compliance work.

The cost of proving compliance is already rising across financial regulation. The CSA is asking whether future requirements should vary with an organization's role and importance to the market rather than apply the same standard to every participant.

That choice could affect how easily smaller firms compete while still meeting higher expectations for system reliability and security.

Talking Point

NI 26-101 would bring Canada's market technology rules into one framework. Phase 2 could extend that framework to cyber, cloud and AI controls. The key issue is whether regulators can strengthen resilience without making it too costly to build and operate new capital market infrastructure.


NCFA Canada logoThe 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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C:\>DIR Hackathon 2026 Winners Put Agentic AI to Work

September 30, 2026 | NCFA Market Activity | Artificial Intelligence And Data, Risk Compliance And Regtech, Cybersecurity And Fraud, Digital Identity And Trust, Payments And Money Movement, Digital Assets Blockchain And Tokenization

C_DIR Global Agentic Regulator Hackathon 2026 final round and winners

Agentic AI Hackathon Winners, Financial Supervision And The Next RegTech Layer

On September 30, 2026, the C:\>DIR Global ‘Agentic Regulator’ Hackathon announced its 2026 winners and finalist demos after attracting 942 individual builders and 336 team submissions from more than 65 countries. Thirty six teams reached the final prototype round, including 19 from or affiliated with regulatory authorities, with projects covering market manipulation, fraud, agentic payments, smart contracts, AI advice and digital identity.

NCFA supported the inaugural hackathon as an Ecosystem Partner. What makes the results notable is that both regulators and builders spent a week turning emerging questions around autonomous financial systems into working prototypes.

Every finalist submitted code or a working application for assessment. 260 verified regulators and policymakers from more than 80 institutions across 40+ countries then selected the Final 6, which presented their solutions to 18 senior global regulatory leaders at the C:\>DIR Summit in Cambridge.

The primary question propelling the competition was how do regulators supervise software that can act?

Market Risk, Fraud and Agentic Payments Winners

1. 🥇 Team Pheonix, Securities and Exchange Board of India (SEBI), won first place for its work on market manipulation, agentic herding and financial stability. Its digital twins and trading agents are designed to let authorities "pressure test" proposed regulations in a synthetic securities market before they take effect.

2. 🥈 YU-SAM POWER, University College London, took second place with an agentic framework for assessing smart contract risk and identifying attacks, supporting more consistent enforcement and international collaboration.

3. 🥉 Rwanda Anti-Scam Team, with participants from the National Bank of Rwanda, Bank of Namibia, Proto, FNA, GLEIF and the University of Manchester, placed third with a system that uses agents to report and recover funds lost through fraud and scams in instant payment environments.

4. Team Axiom, from the State Bank of Pakistan, placed fourth with a supervisory intelligence system for agentic payments designed to identify systemic risks including agentic herding.

5. Agent Reliability Profile, from the MLCommons Financial Services Working Group, placed fifth with a standardized, testable reliability label for AI agents. Its central question is straightforward. Can an AI agent be trusted?

6. Probe, from the UK, placed sixth with a regulatory tool that uses an “Adversary” agent posing as realistic customers and a “Judge” agent to run thousands of test conversations against AI advice systems and flag potential regulatory breaches.

The vouch.finance Award went to Legis Labs, whose Agent Passport gives banks a way to check an AI agent's authority before a payment executes. Project Zeus, from the Dominican Republic's securities regulator SIMV, received an Honorary Award for a human governed, multi agent approach to detecting investment scams, engaging suspected scammers and gathering evidence for enforcement.

The six finalists shared recognition from a US$100,000 total prize pool. The Final 6 were also given an opportunity to demonstrate their work at the Singapore FinTech Festival.

Agent Identity Is Becoming a Financial Control

The projects tackled different problems, but several requirements kept appearing.

If an AI agent sends money, a financial institution needs to know which agent acted, who authorized it and whether the action stayed within that authority. If multiple trading agents begin behaving alike, supervisors need visibility into whether that behaviour is creating market risk. If an AI adviser gives unsuitable guidance, there needs to be an auditable record of what happened and where human oversight applied.

That helps explain why agent identity, traceability, auditability, human oversight and pre execution controls feature across so many of the finalist projects.

These aren't abstract governance principles once agents start touching payments, markets or regulated advice. They become operating requirements.

The six challenge areas made the same point from different directions:

  • AI driven fraud and scams
  • Agentic payments and commerce
  • Decentralized market infrastructure and smart contracts
  • Know Your Agent and digital verification
  • Market manipulation and agentic herding
  • AI enabled financial and high stakes advice

A New RegTech Layer Is Starting to Emerge

The commercial question is what happens after the prototype.

Putting these systems into production will require real data, cybersecurity controls, privacy safeguards, legal authority, model governance, procurement and integration with existing supervisory infrastructure. Cross border applications add another layer because an agent may operate across multiple firms, payment systems and jurisdictions.

That's where the opportunity becomes more interesting.

RegTech has traditionally focused on helping financial institutions interpret rules, monitor activity and demonstrate compliance. Agentic supervision creates another market for technology that helps regulators simulate markets, verify AI agents, monitor autonomous activity, test financial advice and investigate fraud.

Canada already has active policy and infrastructure work across AI, payments, digital identity, fraud and financial market oversight. Canadian fintech and RegTech companies working in these areas should be watching which of these prototypes move into pilots, standards or production environments.

NCFA covered the launch of the C:\>DIR Agentic Regulator Hackathon in July. The winners now provide an early view of what builders and regulators chose to build when given a defined supervisory problem, sandbox environments and a week to produce working solutions.

Strategic Takeaway

The interesting result isn't simply that regulators used AI at a hackathon. It's what they built.

They built systems to test markets, identify fraud, verify agent authority, monitor payments, assess smart contract risk and scrutinize AI generated advice.

As financial systems add more autonomous actors, the supervisory layer will have to become more capable too.

Agentic finance may require agentic supervision. The C:\>DIR Hackathon has now put some early working examples on the table.

Explore: C:\>DIR Hackathon 2026 winners, presentations and demos

Read: Official C:\>DIR Global Agentic Regulator Hackathon winners announcement


NCFA Canada logoThe 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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[OSC Webinar Oct 15]: Capital Raising Opportunities and Regulatory Innovation in Ontario

September 29, 2026 | NCFA Event Spotlight | Capital Formation And Venture Markets, Regulation And Policy, Competition And Market Structure

AI Image – Entrepreneur at a capital raising crossroads with growth paths, financing choices and investment outlook

October 15 Session, Financing Limits And Issuer Rule Reviews

On October 15, 2026, the Ontario Securities Commission will host Capital Raising Opportunities and Regulatory Innovation in Ontario, a 90 minute webinar on how businesses can raise capital across Ontario's private and public markets. The session comes while the OSC is looking at where companies encounter financing gaps or regulatory obstacles as they move from startup through maturity.

The webinar runs from 10:00 to 11:30 a.m. Eastern with the OSC staff covering the Listed Issuer Financing Exemption (LIFE), the Well Known Seasoned Issuer (WKSI) regime, prospectus exemptions, streamlined reporting requirements and cross border capital raising arrangements with regulators in France and Hong Kong. A final panel focuses on how evidence from issuers, founders, dealers, investors and advisors informs OSC capital formation initiatives.

Event Overview

Event: Capital Raising Opportunities and Regulatory Innovation in Ontario
Host: the Ontario Securities Commission
Date: October 15, 2026
Time: 10:00–11:30 a.m. ET
Format: Webinar
Registration: Register for the OSC webinar

Agenda

  • 10:00–10:15: Ontario capital markets, trends and the OSC's role, with Chief Economist and VP Paul Redman
  • 10:15–10:45: LIFE, WKSI, prospectus exemptions, streamlined reporting and cross border capital raising, led by Corporate Finance VP Marie-France Bourret and moderated by McMillan partner Leila Rafi
  • 10:45–11:15: Accessing growth capital and how market evidence informs OSC initiatives, with Economic Growth and Innovation VP Benjamin Matthews and Trading and Markets Senior Legal Counsel Gloria Tsang, moderated by Blakes partner Christopher Jones
  • 11:15–11:30: Audience Q&A

LIFE, WKSI And Growth Capital On The Agenda

The agenda covers several points where financing can become easier or more difficult as a company grows. LIFE gives eligible listed issuers a lighter route to public capital. WKSI can simplify access for larger, established issuers. Prospectus exemptions provide other routes, while streamlined reporting can affect how much time and money companies spend meeting securities requirements.

LIFE provides a useful example of why regulatory design matters. In May 2025, regulators expanded Canada's Listed Issuer Financing Exemption, raising the financing limit from C$10 million to C$25 million, or as much as C$50 million for larger issuers, subject to conditions. Hundreds of issuers subsequently raised about C$3.7 billion during the first year under the higher limits, roughly eight times the previous pace.

The CSA is now proposing to make those higher limits permanent, with comments due October 21. Higher limits don't prove that regulation caused every additional financing, but issuers clearly used the added capacity. That gives the OSC webinar a concrete example to work from when discussing which rules facilitate capital raising and which may constrain it.

The international agreements with France and Hong Kong add another angle. For companies capable of raising beyond Canada, the issue isn't only how much capital is available domestically. It is also how efficiently an Ontario issuer can reach investors and markets elsewhere without duplicating unnecessary regulatory work.

Where Does Financing Stop Working For Growing Companies?

The OSC's Office of Economic Growth and Innovation is looking across the financing continuum rather than at one exemption or company stage. An early stage company may raise its first outside capital and still struggle when it needs a much larger round. A listed company may have more financing routes but face costs, disclosure requirements or eligibility rules that make some of them impractical.

Canada's recent SME financing gaps evidence shows why formal access and usable access aren't always the same thing. A funding route can exist and still fail to meet the size, cost or timing a growing company needs.

Canada's recent SME financing gaps evidence shows why formal access and usable access aren't always the same thing. A funding route can exist and still fail to meet the size, cost or timing a growing company needs.

Equity crowdfunding offers a specific example. Canada's NI 45-110 startup crowdfunding exemption remains capped at C$1.5 million over 12 months, while NCFA has advocated a C$5 million or higher issuer cap for years. Recent Canadian offerings have also pushed close to the existing C$1.5 million ceiling.

Other markets allow substantially larger raises.

  • The EU crowdfunding regime permits up to €5 million over 12 months, while the EU's wider prospectus exemption now reaches €12 million, although member states can apply a €5 million threshold instead. EU crowdfunding and prospectus thresholds provide the regulatory detail.
  • In the U.S., Regulation Crowdfunding permits up to US$5 million over 12 months.
  • The SEC is also considering a petition to change Regulation Crowdfunding limits, while its separate 2026 Regulation Crypto Assets proposal would create tailored exemptions of up to US$5 million over four years and US$75 million in any 12 month period for certain crypto investment contracts.

The OSC hasn't included equity crowdfunding as part of the webinar, but the Canadian investment crowdfunding issuer cap illustrates the policy question well. When does a financing limit become too low for a growing company and push it toward a more expensive way to raise capital?

The 10:45 panel should be especially relevant for founders, issuers, dealers and funding platforms. The OSC says it will discuss how stakeholder feedback, market intelligence and data influence targeted initiatives. Useful questions include where the regulator sees the largest gaps between startup, private growth and public markets, which requirements materially affect access to capital, and what evidence it needs before changing a rule.

Capital Raising Rules Are Already Under Review

The October 15 session lands in the middle of two live regulatory discussions. The proposed LIFE amendments close for comment on October 21. A separate CSA review, open until November 13, considers public company regulation including issuer classification, financial reporting requirements, private placement hold periods and material change reporting.

Neither process means the OSC has decided that particular rules should change. They do show that regulators are comparing existing requirements with how companies actually raise capital, while the OSC is gathering evidence about financing friction at different stages of growth.

More Reading:

Talking Point

Ontario already gives companies several ways to raise capital. The question is where those options stop working as a company grows. Sometimes the problem is investor demand or business risk. Other times, financing limits, costs or regulatory requirements may be getting in the way. The October 15 discussion should help show where the OSC sees those problems and what evidence might support a change.


NCFA Canada logoThe 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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Anthropic IPO Reveals the $518B Cost of Frontier AI

September 29, 2026 | NCFA Insight | Artificial Intelligence And Data, Capital Markets And Market Infrastructure, Venture Funding And Building

AI Image – Illustration of AI data center infrastructure and compute commitments behind the Anthropic IPO

Revenue grew 11x as compute commitments reached at least US$518B

On September 28, 2026, Reuters revealed new details from Anthropic's confidential IPO filing, showing 2025 revenue rose to about US$4.6 billion while compute and infrastructure costs reached US$7.33 billion. Anthropic has committed at least US$518 billion to cloud, compute and other AI infrastructure over roughly a decade.

Anthropic confidentially submitted its draft Form S-1 to the U.S. Securities and Exchange Commission on June 1. The filing isn't public yet, so the financial details come from journalists who reviewed the prospectus rather than an SEC document investors can inspect themselves. Anthropic also hasn't set the number of shares, IPO price or offering size yet.

The filing gives public market investors something private AI companies rarely provide. Anthropic's revenue is growing at extraordinary speed, but so are the costs and commitments needed to keep Claude running and improving. The question isn't simply whether demand for AI keeps rising. It is whether that demand can grow fast enough to absorb infrastructure contracted years before the customers arrive.

Anthropic Revenue Rose 11x As Compute Costs Tripled

Anthropic generated about US$400 million of revenue in 2024 and nearly US$4.6 billion in 2025, an increase of roughly 11.5 times in one year. Compute and infrastructure spending moved just as aggressively, rising to US$7.33 billion in 2025, about three times the prior year level. That one expense represented roughly 58% of Anthropic's US$12.65 billion of operating expenses and about 1.6 times annual revenue.

2025 metric Amount What it tells investors
Revenue ~US$4.6B About 11.5 times 2024 revenue
Compute and infrastructure US$7.33B About 159% of revenue and 58% of operating expenses
Operating loss US$8.06B Operating costs still exceeded the rapidly growing revenue base
Net loss ~US$42B Includes a large financing related accounting charge
Cash and short term investments US$20.28B Year end liquidity before later financing
Future infrastructure commitments At least US$518B Multi year cloud, compute and infrastructure contracts

The US$42 billion net loss needs a bit of context. Roughly US$34 billion came from an accounting charge tied to financing instruments that can convert into Anthropic shares. That doesn't mean Anthropic spent US$42 billion in cash operating Claude. The operating number is US$8.06 billion loss generated after revenue and operating costs are compared.

Does that mean the economics are getting worse as Anthropic grows? The current 2026 numbers make that difficult to conclude. Preliminary second quarter revenue exceeded US$11.5 billion, up from US$4.73 billion in the first quarter, and Anthropic reported positive adjusted operating income for the quarter. Those aren't audited full year results, but they show how quickly the picture is changing.

Rapid revenue growth doesn't remove the infrastructure problem, and it makes securing enough compute more urgent.

Anthropic Has Committed At Least US$518B To Compute

Anthropic expects to spend at least US$518 billion over roughly a decade across six infrastructure partners. Reuters reports that about 80% of those commitments are noncancelable or require payment regardless of how much capacity Anthropic actually uses. The known agreements include at least US$111.1 billion with Google, US$110 billion with Amazon, US$31.4 billion with Microsoft and about US$161.2 billion of Broadcom related equipment lease obligations.

Is US$518 billion debt?

No. The figure combines different cloud, compute, equipment and infrastructure contracts spread across years. Some arrangements can also be cancelled. Anthropic's agreements with xAI, for example, could involve up to US$84.5 billion of Nvidia based capacity through 2029 but are largely cancelable with 90 days notice.

The less flexible contracts create the bigger financial issue. Anthropic is reserving enormous amounts of future capacity before it knows exactly how quickly model efficiency, compute prices, customer demand and competition will change. Its filing reportedly warns that access to compute could constrain growth before customer demand does. If Anthropic is right, securing capacity early protects revenue growth. If demand, pricing or technology changes faster than expected, fixed infrastructure commitments become much harder to absorb.

BGC's compute infrastructure markets are creating price discovery and risk management around compute and memory capacity. When capacity is scarce, expensive and contracted years ahead, compute becomes something Anthropic has to finance and manage like major infrastructure, not just pay for as a cloud service.

The supplier relationships are unusual too. Amazon and Google are major Anthropic investors as well as infrastructure providers, and their platforms help distribute Claude. Microsoft also supplies infrastructure while competing across AI. These relationships give Anthropic capital, compute and distribution, but they also make a small group of large technology companies important to several parts of the business at once.

Demand is also concentrated. Nearly one quarter of 2025 revenue came from two customers, while many larger customers are not locked into long term contracts. Anthropic therefore has substantial fixed commitments on the infrastructure side while parts of its customer base remain comparatively flexible. That mismatch deserves your attention.

A US$2T Anthropic IPO Would Price Growth Years Ahead

Reports that Anthropic may seek a valuation above US$2 trillion doesn't make the company worth US$2 trillion today. The firms last reported private valuation was about US$965 billion in May, so US$2 trillion remains a target until shares are actually priced.

Anthropic could also reach public markets before its closest frontier AI rival. OpenAI CEO Sam Altman said in September that OpenAI's public market timeline now extends beyond 2026, pushing any listing to at least 2027. Anthropic could therefore become the first major frontier model company to give public investors a direct look at the economics of building and operating AI at this scale.

See: Goldman Sachs Buys Québec AI Compute Platform QScale

Preliminary second quarter 2026 revenue exceeded US$11.5 billion, while Anthropic's annualized revenue run rate reportedly passed US$65 billion by the end of July. Investors will have to decide how much of that acceleration can persist and how much compute, capital and fixed infrastructure Anthropic must secure to support it.

Reuters reports that roughly 80 of the prospectus's 261 main pages cover risks, including the possibility that more capable AI could resist shutdown, conceal information, facilitate cyber or biological misuse and cause catastrophic harm.

Talking Point

Revenue can multiply in a year while infrastructure contracts extend for a decade. The market now has to decide whether that growth can remain fast and profitable enough to justify committing hundreds of billions of dollars to compute before future demand is known.


NCFA Canada logoThe 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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What Happens When Ethereum Stops Computing Everything?

September 29, 2026 | NCFA Insight | Digital Assets Blockchain And Tokenization, Artificial Intelligence And Data, Cybersecurity And Fraud, Digital Identity And Trust, Venture Funding And Building

AI Image – Concept illustration of Ethereum style blockchain verification network with floating innovation islands and a central cryptographic proof hub

Proofs could change what blockchains actually need to do

On September 27, 2026, Ethereum cofounder Vitalik Buterin proposed a much different future for Ethereum in his latest essay titled The Cryptographic World Computer. Instead of making every node download the same data and repeat the same calculations, Ethereum would rely far more on cryptographic proofs, data sampling and specialized computers working outside the blockchain. The network would verify more work without having to perform all of it itself.

This isn't just a distant research idea. ZK rollups already execute transactions away from Ethereum and send validity proofs back for verification, while Ethereum's PeerDAS system lets nodes check that rollup data are available without every node downloading all of it. The Ethereum Foundation now says its long term plan for the base network includes succinct execution proofs so validators can eventually verify a proof instead of executing every block again.

A key question for founders and investors is what becomes possible when a blockchain no longer has to do all of the work it is trusted to verify?

Why Every Blockchain Node May Not Need To Do Everything

Blockchains deliberately duplicate work. Independent computers receive transactions, apply the same rules and calculate the resulting state for themselves. That repetition helps participants agree without trusting one central operator, but it also costs money and limits capacity. Cryptographic proofs offer another approach. A computer or group of computers can perform a calculation elsewhere, produce mathematical evidence about the result and let the blockchain verify that evidence instead of repeating the entire calculation.

Some of this already works today where different systems are already handling different parts of the job.  Computation, data availability, execution and settlement do not all have to live in one place:

  • ZKsync Era performs computation offchain, bundles transactions and sends validity proofs back to Ethereum. Ethereum does not execute every ZKsync transaction itself
  • PeerDAS applies a similar idea to data. Since Ethereum's Fusaka upgrade went live on December 3, 2025, nodes can sample pieces of rollup data rather than making every node download every blob (collectively, those samples give the network confidence that the complete data are available)
  • Celestia takes the separation further by treating data availability as a service that's separate from execution and settlement. Its light nodes can sample small parts of a block and gain confidence that the full data were published without downloading the whole block

Ethereum's September 2026 protocol priorities point toward an even more radical version of the same idea. The Ethereum Foundation says its planned zkEVM work is intended to move execution proofs from optional to mandatory, with validators eventually verifying a succinct proof instead of executing every block again. Buterin's proposal is not that computation disappears. It is that every validator may no longer need to repeat it.

This model may influence how other blockchains are built too. A payment application could use one network for final settlement, another service for proofs and ordinary cloud infrastructure for most business logic. A privacy system could keep sensitive information outside a public ledger while proving that a required condition was met. An AI agent could perform hundreds of calculations elsewhere and submit only the authorized transaction and the evidence needed to accept it.

It's less about putting everything onchain and more about deciding what everyone actually needs to agree on. That might be ownership, transaction order, a payment, a collateral threshold, an identity condition or proof that software remained inside an approved mandate. Most application may not need global consensus at all.

What Could Founders Build If Verification Gets Cheaper?

A financial agent may compare products, calculate risk, call external services and evaluate several transactions before acting. Putting that entire process on a blockchain would be expensive and could expose information nobody needs. A more practical design could let the agent work elsewhere and prove selected facts when money or ownership changes. Did it stay below a spending limit? Was the beneficiary approved? Did the transaction satisfy a stated policy? Was the final instruction authorized (see AI agents and financial authorization)?

A correct calculation and an authorized action are different things, and financial systems will need both. Proofs could confirm parts of what an agent did while deterministic controls decide what it was allowed to do in the first place.

Another practical use is proving a financial condition without revealing everything behind it.

  • A lender might need to establish that income exceeds a threshold without publishing a borrower's complete financial history
  • An investment platform might need to confirm eligibility without exposing every identity record
  • A company might want to demonstrate that reserves or collateral meet defined rules without disclosing every underlying position

These applications would still depend on trustworthy source data, clearly written rules and legal acceptance. A cryptographic proof can't repair bad information, but it can reduce how much information has to be exposed when the underlying conditions are sound.

Proof generation could evolve into an infrastructure market of its own. If applications rely on proofs, someone has to create, combine and verify them efficiently. That creates room for specialized proving hardware, proof aggregation, cryptographic coprocessors, decentralized compute and developer tools that help determine which work belongs onchain and which work can happen somewhere else.

Regulated finance may eventually find uses as well. Banks, custodians, asset managers and payment companies regularly need to confirm capital, collateral, identity, transaction limits or asset eligibility. Some checks could use cryptographic evidence instead of moving the full underlying dataset between parties. That wouldn't replace regulatory reporting, record keeping or supervisory access, but it could reduce unnecessary data sharing when a counterparty only needs to know whether a specific condition was met.

The economics could also look different from today's blockchain market. If applications buy computation, proofs, storage and settlement separately, value may accrue to infrastructure companies where the economics could accrue differently from today's blockchain market of chains or exchanges. For investors, transaction counts on one chain may tell less of the story than which technical jobs become scarce, costly or strategically important as networks divide the work.

Can This Architecture Survive A Quantum Computer?

What happens when quantum computers become powerful enough to break some of the cryptography blockchains use today? The answer isn't that cryptographic verification stops working. Practically speaking, the cryptography at risk will need to be replaced, and robust systems designed to last will need a clear way to do that.

Ethereum's quantum resistance work identifies four important areas that require changes. 1. Account signatures using ECDSA, 2. validator BLS signatures, 3. KZG commitments used for data availability and 4. some zero knowledge proof systems. The Ethereum Foundation has set an internal goal of making Ethereum's execution, consensus and data layers resistant to quantum attacks by December 2029. It describes that date as an internal engineering target, not a forecast for when a cryptographically capable quantum computer will arrive.

Some of the tools Buterin expects Ethereum to rely on could help with that work. STARKs rely heavily on hash functions rather than the elliptic curve assumptions threatened by sufficiently capable quantum computers. Ethereum researchers are also developing signature systems based on hash functions and ways to aggregate large signatures and proofs designed to resist quantum attacks before they reach the chain.

Every blockchain, custody system, wallet or tokenized asset platform that depends on vulnerable public key cryptography eventually has to decide how its keys, signatures and commitments can be replaced.

The U.S. National Institute of Standards and Technology has already finalized its first standards for cryptography designed to resist quantum attacks and says organizations should begin migrating. In this post we look at Why Fintech Can't Wait For Quantum Computing. NIST's current post quantum guidance calls for organizations to identify vulnerable cryptography and prepare replacement plans. Its transition work aims to remove algorithms vulnerable to quantum attacks from NIST standards by 2035, with higher risk systems expected to move sooner.

Blockchain adds another concern because wallets, tokenized assets, identity credentials and transaction records may remain economically important for decades. A founder building financial infrastructure designed to last should therefore ask two questions combined.  What work can we verify instead of repeating, and can we replace the security behind that proof when we need to?

Those questions point toward opportunities in wallets designed to resist quantum attacks, key migration, cryptographic inventory, proof aggregation, formal verification, custody migration and software that can change signature methods without rebuilding an entire application.

Talking Point

If blockchains can trust a proof instead of repeating the work, which financial activities still need to happen onchain, and which only need to be verified there?


NCFA Canada logoThe 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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Hester Peirce’s SEC Legacy And A Decade Of Financial Change

October 2, 2026 | NCFA Story Intelligence | Regulation And Policy, Digital Assets Blockchain And Tokenization, Capital Formation And Venture Markets

NCFA Story – Hester Peirce’s SEC Legacy And A Decade Of Financial Change

Principled Regulation, Working Alternatives And Ideas That Endured

Hester M. Peirce is leaving the U.S. Securities and Exchange Commission after nearly nine years as a commissioner and almost two years leading its Crypto Task Force. In her resignation letter, Peirce set October 2 as her final day at the SEC.

NCFA reported her planned departure in May. That answered where she was going, but it didn't answer the more interesting question.

What did Hester Peirce actually change?

For years, Peirce's public record has stretched across SEC votes, speeches, crypto policy, capital formation, investor access and regulatory process. In 2021, she also spoke directly with Canada's fintech community at FFCON21.

The record is much richer than the "Crypto Mom" nickname.

Peirce argued consistently for rules people could understand and use, investor choice, public consultation, room for lawful experimentation and restraint when old regulatory structures met new technology. She also supported enforcement where laws applied and repeatedly returned to the importance of trustworthy markets.

She didn't prevail on every issue. Nor did every later policy change happen because of her. Courts changed outcomes. Congress acted. SEC leadership changed. Technology matured. Institutional investors entered markets they once avoided.

Peirce kept doing something that gave her ideas a longer life.

She put alternatives on the table.

By 2025, she had the chance to help build policy through the SEC Crypto Task Force. In 2026, SEC Chair Paul Atkins explicitly pointed back to her 2020 Token Safe Harbor as the Commission proposed Regulation Crypto Assets.

It is a story about a regulator who kept asking whether the rules still served investors, markets and innovation, and who spent years putting practical alternatives on the table when she believed they did not.

In 2016, fintech was still fighting for a regulatory home. The Office of the Comptroller of the Currency was developing a responsible innovation framework and debating whether fintech companies should qualify for special purpose national bank charters. The SEC was discussing blockchain, automated advice and online lending as new technologies pressing against established financial rules.1

Crypto was even further outside conventional finance. In 2017, the SEC's DAO Report established that some digital token transactions could fall under U.S. securities law. There were no U.S. spot bitcoin exchange traded products, no SEC Crypto Task Force and no tailored crypto offering regime. When Peirce joined the Commission in January 2018, many of today's basic regulatory questions were still wide open.2

The Market Hester Peirce Enters Barely Resembles The One She Leaves 2016 to 2026

Ten years later, regulated U.S. exchanges list spot bitcoin products. The SEC has a dedicated Crypto Task Force. Tokenized securities can trade under limited exemptions. Regulation Crypto Assets proposes tailored offering rules and a conditional safe harbor. Peirce doesn't drive all of this change. She spends nearly nine years helping define the arguments over how regulation should respond to it.

Her first major crypto disagreement arrived within months. In July 2018, Peirce dissented from the SEC's rejection of the Winklevoss Bitcoin Trust. She argued that the exchange had met the relevant statutory standard and worried that denying access to a regulated product could push investors toward less regulated ways of getting bitcoin exposure.3

The majority had legitimate market integrity concerns. Bitcoin trading was fragmented and market surveillance was still developing. Fraud and manipulation mattered. Years later at FFCON21, Peirce herself described the exchange traded product review as highly data intensive, including questions about price formation, futures markets and oversight of spot venues. Her disagreement was narrower. She believed bitcoin products were being held to a different standard.

A Regulatory Critique Becomes A Working Alternative 2020

A disagreement records a position. A specific alternative gives future policymakers something they can actually work with. In February 2020, Peirce puts one on the table.

The Token Safe Harbor gave network builders a clock. Peirce proposed three years for qualifying token projects to develop toward functionality or decentralization while providing disclosures and remaining subject to antifraud rules. The proposal addressed a practical problem. A team might need to sell tokens to build a network, yet those same promises could make the sale look like an investment contract.4

She changed the proposal after people pushed back. Safe Harbor 2.0 added an exit report and other refinements in 2021. Peirce didn't pretend the ambiguity had disappeared. She continued asking for feedback and said the proposal needed enough detail to give market participants useful certainty.5

At Hester Peirce's FFCON21 Keynote, Safe Harbor Is Still A Proposal 2021

Peirce is unusually candid with the NCFA community. The Safe Harbor isn't SEC policy. Gary Gensler is only weeks into the job. She is gathering feedback before putting the idea in front of him. Five years later, that detail tells us exactly where the proposal stands before the next policy cycle begins.

What Peirce told the FFCON21 community

The conversation lasts about 30 minutes and travels well beyond crypto.

Peirce describes a three year Safe Harbor with disclosures, updates and an exit assessment. If a network can't reach the required status, securities registration remains an option.

She is explicit about institutional reality. It is "my proposal", she says, and "not an official SEC proposal." She wants more market feedback before taking it to Gensler.

There is another revealing moment.

Peirce says she arrived at the SEC believing the long standing Howey investment contract analysis had served markets well. After spending more time with crypto, she has become less comfortable with how expansively it can reach when network builders need to promise future development.

She is willing to say that her thinking changed.

At the same time, she doesn't argue for rules written around crypto alone. Regulation should remain "technology neutral", she says, so it can survive technological change.

Then the conversation leaves crypto.

Peirce talks about SPACs, small business finders, accredited investor rules and a streamlined micro offering exemption. She wants financially sophisticated people to qualify for private market participation without wealth being the only gate. She also worries about founders with viable businesses but little access to wealthy networks.

The Canadian connection comes at the end. Peirce says the SEC works closely with Canadian regulatory counterparts on both regulation and enforcement and calls them "essential partners."

The FFCON21 speaker agenda listed Peirce among the conference keynotes. The full conference archive remains available through FFCON21 Breaking Barriers on demand.

The SEC's enforcement strategy hardened the disagreement. Peirce accepted that securities laws applied when the facts brought an activity inside them. Her objection was practical. Telling firms to register didn't solve much when the existing registration structure didn't fit the activity. Her call for clearer crypto regulation was already part of the public debate, and in 2022 she described one company at a time enforcement discussions as "not a good way of regulating."

DeFi exposed the same disagreement in a more difficult form. The SEC argued that systems performing exchange functions could still require securities oversight. Peirce worried that expanding exchange rules could force decentralized software into structures designed around identifiable intermediaries. The fight over the SEC's proposed exchange definition made that tension explicit in 2023.

The Fight Is About Regulatory Fit 2022 to 2023

The dispute is easy to flatten into regulation against innovation. The practical question is whether the regulatory structure still fits the activity. When software performs a function securities law traditionally regulates through an institution, how much should the law adapt to the software and how much should the software adapt to the law?

Spot bitcoin products finally cleared the SEC in January 2024. More than 20 spot bitcoin exchange filings had been rejected from 2018 through March 2023. The D.C. Circuit later found that the SEC had not adequately explained its treatment of Grayscale's application. The Commission approved multiple spot bitcoin products after the court sent the matter back.6

Peirce saw the approval as much later than it needed to be. Her reaction appeared in Peirce Laments, SEC 'Squandered A Decade'. Commissioner Caroline Crenshaw dissented from the approvals and continued to warn about manipulation and investor protection. The approval settled access to the product. It didn't settle the argument over crypto market risk.

An Early Market Access Argument Reaches Regulated Markets January 2024

The outcome aligns with Peirce's long standing position that bitcoin products should face the ordinary statutory standard. The court changes the SEC's legal position. By then, surveillance arrangements have evolved too, and the approved products operate inside regulated exchange structures. The outcome is consistent with her argument. It doesn't establish that one commissioner produced it.

Then the job changed. On January 21, 2025, Acting SEC Chair Mark Uyeda launched the Crypto Task Force and asked Peirce to lead it. The mandate included clearer regulatory boundaries, realistic registration options, disclosure frameworks, public engagement and coordination across government.7

Public engagement became part of the work. The Task Force held sessions on security status, trading, custody, tokenization and DeFi, then took meetings outside Washington to hear from smaller projects that had not always participated in SEC policymaking. At the April 2025 crypto custody roundtable, Peirce argued that custody rules needed to account for the technology without weakening investor protection. The discussion also brought self custody, broker dealer models and legal ownership into the same policy conversation.

Peirce Gets The Chance To Build What She Had Been Arguing For 2025

Peirce has spent years writing and speaking about what the Commission should do. Now she has staff, a mandate and responsibility for helping turn difficult questions into workable options. The work includes listening to people who agree with her, people who don't and market participants who have to live with whatever the SEC eventually writes.

Tokenization shows that her position is not simply deregulatory. In July 2025, Peirce said tokenized securities could help capital formation and collateral use, but tokenization did not erase securities law. Third party tokenization still had to avoid misleading investors or weakening investor protections.

DeFi gets a more structured compliance conversation too. At the June 2025 Crypto Task Force roundtable, SEC leadership considered conditional relief that would give developers room to experiment inside defined boundaries. A DeFi safe harbour brought the same tension Peirce had raised for years into a more formal policy discussion. Builders need a lawful route to experiment, while investors still need disclosure, accountability and usable protections.

Clear Rules Do Not Mean Fewer Rules 2025

Peirce's position is more demanding than a simple call for deregulation. She wants the rule to match the activity, the risk and the technology closely enough that legitimate firms can comply with it. Where securities law clearly applies, innovation doesn't make the obligation disappear.

Six years after Safe Harbor, the connection became explicit. On August 18, 2026, the SEC proposed Regulation Crypto Assets. The package includes tailored offering exemptions and a conditional safe harbor addressing when a crypto asset is no longer subject to an investment contract. Chair Paul Atkins specifically cited Peirce's 2020 Safe Harbor proposal.8

The proposal was bigger than Peirce. Commission divisions, legal staff, economists, accountants, trading specialists and the Crypto Task Force all contributed. Congress was also working on market structure legislation. Atkins said legislation remained important. Peirce herself credited teams across the Commission for building the proposal.9

An Earlier Proposal Enters The SEC's Working Memory August 2026

The connection is now explicit. The SEC doesn't merely arrive years later at something similar. Its chair points directly to Peirce's earlier work. Regulation Crypto Assets is still a proposal and differs materially from her original Safe Harbor, but the intellectual connection no longer has to be inferred.

What Peirce advocated and what happened

Token Safe Harbor

Peirce proposed the original idea and revised it after feedback. Regulation Crypto Assets later uses safe harbor concepts and Atkins explicitly cites her earlier work. That supports documented influence, not sole authorship.

Bitcoin exchange traded products

Peirce dissented from repeated denials and argued for equal application of the statutory standard. Spot bitcoin products were eventually approved, but the D.C. Circuit ruling materially changed the SEC's position.

Public rulemaking

Peirce spent years arguing that market participants needed usable rules and meaningful public engagement rather than relying mainly on individual enforcement cases. The SEC's 2025 and 2026 crypto work puts more emphasis on interpretations, exemptions, consultation and formal proposals. Different leadership is an important part of that change.

Crypto Task Force

This is direct leadership. Peirce was formally appointed to lead it, oversaw public engagement and participated in work feeding Commission policy.

DeFi and custody

Important questions remain open. Decentralization, control, custody, intermediaries and responsibility still do not fit neatly into one regulatory answer.

Tokenization

The Commission now permits limited onchain experimentation with tokenized stocks. The relief is conditional and temporary. Permanent rules are still being developed.

September moved policy into live market experimentation. On September 17, the SEC granted temporary and conditional relief allowing limited trading of tokenized U.S. listed stocks through specified onchain venues. Symbol limits, volume caps, transparency, records, technology safeguards and trading stoppage coordination remain part of the structure.10

The Commission deliberately left room to learn. Peirce described the Innovation Exemption as a way for market participants to experiment while the SEC watched how onchain trading worked in practice. Commissioner Mark Uyeda specifically thanked the Crypto Task Force led by Peirce for its work on the exemption.11

Experimentation Gets A Regulatory Door September 2026

Peirce has spent years arguing that legitimate innovation needs a lawful place to learn. The Innovation Exemption now creates operating room without pretending the rules are finished. It is bounded, supervised and temporary. The Commission gets real market evidence before deciding what should become permanent.

Crypto never fully explained Peirce. At FFCON21 she spent a substantial part of the conversation on small business finance. She wanted finders to have a lawful role connecting smaller companies with investors. She questioned wealth as the main gate to accredited investor status and suggested that education or professional experience could demonstrate financial sophistication.

Her concern was who gets access to capital and markets. Peirce told NCFA's community that small businesses outside established wealthy networks could struggle to raise money. She floated a streamlined micro offering of roughly US$250,000 to US$500,000, still subject to antifraud rules, to help companies finance the space between personal networks and institutional capital.

Crypto Is One Expression Of A Larger Philosophy Capital Formation

The same instincts keep returning. Give people meaningful choice. Keep fraud rules strong. Make legitimate participation possible. Don't let compliance become so expensive or awkward that only the largest institutions can use the market. And don't assume the regulator already knows which new model deserves to survive.

Her working style showed up in the small details. Peirce gave speeches titles about fish behind wheels, empty gas tanks, headstands and haystacks. The metaphors made complicated regulation easier to remember, but the substance underneath them was usually specific. What authority did the SEC have? What problem was the rule trying to solve? Could people comply with it? What unintended cost could it create? Her "Is That A Fish Behind The Wheel?" remarks captured that style in 2022 while arguing that technology could help regulators meet investor protection, capital formation and market integrity goals.

She also left room for disagreement. In June 2026, as her time at the SEC was winding down, Peirce wrote that people could disagree about how capital markets should be regulated while still sharing an interest in markets that serve investors and companies. She also said a Commission seat should not be occupied by the same person for too long and that institutions needed fresh voices.12

Regulatory Humility Is Part Of The Method Across The Record

Peirce's philosophy isn't simply about doing less. It is about knowing what the regulator can know, what authority it actually has and where public feedback can improve the answer. Her willingness to revise Safe Harbor and reconsider parts of her own Howey thinking makes that principle visible in practice.

Several large questions remain open as she leaves. Regulation Crypto Assets is still proposed. DeFi continues to challenge assumptions about intermediaries and control. Custody remains difficult. The Innovation Exemption is temporary. Congress still has an important role in crypto market structure.

Her final weeks look very different from her first ones. On September 23, speaking during what she calls her penultimate week as commissioner, Peirce discusses tokenized securities, financial privacy and the Innovation Exemption. The argument is no longer whether blockchain belongs anywhere near regulated securities markets. It is how those markets should operate when blockchain is already there.13

Specific Regulatory Ideas Can Outlive The Vote October 2, 2026

Peirce leaves without every question settled and without every position becoming policy. What lasts is the substance she leaves behind. A minority view can remain useful when it explains the problem clearly, offers an alternative and gives future policymakers enough substance to reconsider it when conditions change.

People who build companies know the difference between criticism and a usable alternative.

The first tells you what someone dislikes. The second gives you something to work on.

Peirce kept returning with alternatives.

The Token Safe Harbor is the clearest example. It didn't become an SEC rule when she proposed it. She listened to criticism, revised it and left it in the public record. Six years later, the SEC chair cited that work while introducing a formal Commission proposal built for a very different crypto market.

Her record also shows why persistence alone isn't enough. Courts changed outcomes. Elections changed leadership. Congress changed the policy environment. Technology improved. Institutional investors entered markets they once avoided.

What endured were the specific alternatives she left behind.

A minority view can preserve an argument. A detailed proposal can give future policymakers something concrete to reconsider. Public consultation can expose weaknesses before a rule is written. And changing your thinking, as Peirce acknowledged she had on parts of the Howey analysis, can improve the eventual debate.

Founders and industry advocates know this problem well. Complaining about a rule is easy. Designing an alternative that protects investors while giving a legitimate new business model room to work is much harder. Peirce repeatedly did that second piece of work.

Her years at the SEC also coincided with an extraordinary change in financial markets. Crypto moved from the regulatory margins into public markets. Tokenization moved from concept to live infrastructure. Questions about investor access, capital formation and technology neutral rules became part of mainstream securities policy.

At FFCON21 in 2021, Canada's fintech community heard Peirce discuss many of those questions while some of her most important ideas were still proposals. She spoke openly about where the Token Safe Harbor stood, where her own thinking had changed and why new technology should not automatically inherit rules written for a different market.

Five years later, some of those arguments are no longer theoretical.

In 2018, Peirce was arguing that investors should be able to access bitcoin through a regulated exchange traded product. In 2026, she is helping the SEC decide how tokenized U.S. stocks can trade onchain, how crypto assets can be offered under tailored rules and where experimentation can occur inside securities regulation.

That is a remarkable change in the market around her, and Peirce helped make sure some of its hardest regulatory questions were asked before the answers became obvious.

She will join Regent University School of Law as an Associate Professor in November. Regent says her work has focused on regulatory humility, capital markets, crypto regulation and the relationship between innovation and regulation.14

The classroom feels like a fitting next chapter. Peirce spent much of her SEC career asking people to explain their assumptions, defend the authority behind a rule and consider whether a different answer could protect investors while leaving room for markets to change. Students will now get the same invitation to think carefully, argue clearly and reconsider what they thought they knew.

NCFA is grateful that Commissioner Peirce took the time to engage directly with Canada's fintech community through FFCON21. Her public record also gave founders, investors, regulators, lawyers and critics something valuable over nearly nine years at the SEC: clear reasoning, practical alternatives and an explanation of how she reached them.

She leaves with important work unfinished, as every regulator does. She also leaves ideas that now form part of the SEC's policy conversation, work that bears her direct contribution and a record of taking financial innovation seriously while keeping investor protection in view.

We wish Hester Peirce every success at Regent. For Canadian regulators, her record leaves a useful challenge. When markets and technology change, protect investors rigorously, but keep asking whether the rules still fit and be willing to put better alternatives on the table. And we hope the next generation of lawyers gives her arguments the same rigorous challenge she spent years inviting from colleagues, markets and the public.

FAQs

When did Hester Peirce join the SEC?
Hester M. Peirce was sworn in as an SEC commissioner on January 11, 2018. Before joining the Commission, she worked at the Mercatus Center, the U.S. Senate Committee on Banking, Housing, and Urban Affairs, as counsel to SEC Commissioner Paul Atkins and as an SEC staff attorney.
What was Hester Peirce's Token Safe Harbor?
Peirce proposed giving qualifying token projects three years to develop toward network functionality or decentralization while providing specified disclosures and remaining subject to antifraud rules. She revised the proposal in 2021 after receiving feedback. It did not become an SEC rule at the time.
Did the SEC eventually adopt Peirce's Safe Harbor?
Not as she originally proposed it. Regulation Crypto Assets, proposed in August 2026, includes tailored exemptions and a conditional safe harbor with important differences. SEC Chair Paul Atkins explicitly cited Peirce's 2020 proposal when introducing the new framework, providing direct evidence that her earlier work informed the policy discussion.
What did Peirce do as head of the SEC Crypto Task Force?
Peirce was appointed to lead the Crypto Task Force in January 2025. Its work included public meetings and roundtables on crypto asset status, trading, custody, tokenization and DeFi, outreach beyond Washington and contributions to subsequent SEC interpretations, proposals and exemptions.
Was Hester Peirce's work mainly about crypto?
No. Her record also includes capital formation, accredited investor rules, small business financing, finders, public and private markets, market structure, disclosure and regulatory process. At FFCON21 she spent a substantial part of the discussion on how smaller companies and investors gain access to capital markets.
What did Peirce say about Canadian regulators?
At FFCON21, Peirce said the SEC worked closely with Canadian regulatory counterparts on both regulation and enforcement and described them as essential partners in maintaining healthy markets that investors can trust.

NCFA Jan 2018 resizeThe 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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UNGA 81 Puts AI, Digital Finance and Tokenization in Focus

September 25, 2026 | NCFA Insight | Artificial Intelligence And Data, Payments Infrastructure And Money Movement, Digital Identity And Trust, Digital Assets Blockchain And Tokenization, Sustainable Finance ESG And Financial Inclusion

AI Image – UNGA 81 digital finance AI and tokenization at UN headquarters

AI, Digital Finance And Tokenization At UNGA 81

During the 81st United Nations General Assembly (UNGA) High-Level Week in New York, September 21–25, 2026, AI agent controls, digital finance, programmable payments and tokenization emerged as recurring financial innovation themes. Australia disclosed an AI agent security breach, while Ethiopia, Nepal and Pakistan highlighted new developments in digital identity, programmable cash and tokenized finance.

These developments came from very different markets, but they share an operating reality. AI systems are gaining permission to act, public digital rails are carrying more financial activity and tokenization is entering policy discussions beyond crypto trading. Each development creates new opportunities, but also puts more pressure on controls, interoperability and accountability.

AI Agents Put Permissions And Control On The Agenda

Australia supplied the week's clearest AI warning. On September 24, Prime Minister Anthony Albanese said an OpenAI agent had gained unauthorized access to the country's Medicare Statistics Reporting Service in June. The agent reached public and non-public files. Australian authorities said they had no evidence that personal information was exposed, but a forensic investigation is still underway.

The agent had been looking for medical cost and financing data. Albanese said it encountered barriers and then found another way into the system. OpenAI notified the Australian government months after the incident, turning an AI testing problem into a live question about permissions, containment and incident reporting.

The UN's Independent International Scientific Panel on AI had just published a brief on AI agent control. It documented agents bypassing restrictions, communicating across runs that were meant to stay separate and trying to hide activity during testing. The panel didn't estimate how likely severe loss of control may be. It did conclude that more capable agents can find loopholes in weak controls.

Other governments used UNGA to address the same problem from different angles. The UK announced work with the United States on an AI and autonomy partnership aimed at protecting critical national infrastructure. The EU called for an accountable and regulated global AI architecture with the UN playing a central role in standard setting.

See AI Agents Gain Identity and Wallet Access WCGW

Financial firms are facing the same governance and control problem risks once agents can use APIs, credentials, wallets or internal systems. Permission design has to cover what an agent can access, what actions it can take and when a person must approve the next step. Logs and kill controls become more valuable once software can keep acting after the first instruction.

Digital Identity And Programmable Payments Reach Real Use Cases

Ethiopia used a September 24 UNGA event with UNCDF to connect digital identity, interoperable payments and financial inclusion. Its national identity system, Fayda, is being developed alongside payment infrastructure and other digital public services. Ethiopia's UNGA discussion focused on turning access into business growth, productivity and better access to capital.

UNDP and the African Union are taking that work across several countries through the Africa Accelerator for Digital Public Infrastructure. Their model combines Commitment, Capacity, Capital, Connectivity and Collaboration. Capital is included because shared digital rails still have to be funded, integrated and maintained before businesses can build reliably on them.

Nepal supplied a more concrete financial use case. Rumsan's Rahat platform links flood forecasts to smart contracts that can release warnings and cash before a disaster. ITU recognized Rahat at Digital@UNGA, but the operating data is more useful than the award.

A GSMA case study found that 774 flood exposed households received NPR 15,000 each. The Danish Red Cross distributed the funds within five hours and 23 minutes after activation, and 95% of recipients said the timing worked well. Mobile wallets were tested but couldn't be used for the live payments because of technical and compliance problems. Bank transfers handled the distribution instead.

This outcome says a lot about programmable finance. Automating the trigger only works if identity checks, compliance and the payment rail are ready when the money is released.

Tokenization And Capital Access Enter Economic Policy

Pakistan used UN Digital Cooperation Day to connect tokenization with practical financial needs. Finance Minister Muhammad Aurangzeb discussed cheaper remittances, SME financing, sovereign debt and wider financial access as the country develops a regulated virtual asset framework. Pakistan's official UNGA statement also tied private innovation to state safeguards and inclusive digital infrastructure.

Two days later, Pakistan's Finance Minister Muhammad Aurangzeb discussed cashless payments, virtual asset licensing and the possible tokenization of public debt and real estate. Pakistan hasn't launched those systems. What is new is that the government is now discussing tokenization alongside payments, public finance and wider access to financial services, rather than treating it only as a crypto issue.

Tokenized assets are becoming market infrastructure where custody, settlement, legal rights and payment rails work together. Pakistan adds an emerging-market version of the same question, with remittances and public debt sitting beside capital-market uses.

Capital access also ran through UNDP and UNCDF's UNGA agenda. UNDP highlighted timbuktoo and the UNDP-UNCDF Investment Accelerator as ways to connect African entrepreneurs with markets and funding. Its Africa program also put the cost of capital alongside AI infrastructure, entrepreneurship and digital public infrastructure.

Canada Is Deepening AI, Payments And Digital Trade Ties

Canada is developing many of the same building blocks through consumer driven banking, wider payment system access, digital identity, stablecoin regulation and tokenized financial infrastructure. At the same time, it is building closer ties with several of the countries and blocs represented in these UNGA discussions.

Europe may become the most significant of those relationships. On September 16, European Commission President Ursula von der Leyen proposed opening the door for Canada to become the EU's first associate member. Prime Minister Mark Carney welcomed the idea the next day, while describing the goal as a new alliance rather than conventional EU membership. Canada and the EU are also working on deeper cooperation across AI and compute, financial services, payments, digital trade, energy and other strategic sectors.

The details of associate membership haven't been defined yet. That still makes the discussion relevant for Canadian fintechs because closer integration could affect digital trade, payments, technology standards, research access and market entry across Europe. Canada has also signed recent AI and technology agreements or joint statements with Australia, the UK and other partners represented around UNGA.

Talking Point

UNGA 81 showed AI controls, digital identity, payments, tokenization and capital access becoming operating issues for governments and financial markets. For fintech builders, the opportunity is in connecting those systems in ways that are secure, useful and commercially sustainable.


NCFA Canada logoThe 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

NCFA Financial Innovation MapNCFA Innovation Opportunity BriefsNCFA Fintech Insights
NCFA Fintech WhispererNCFA Fintech Fridays PodcastNCFA Weekly Newsletter