Karsten Wenzlaff, Advisor
August 26th, 2025
Cybersecurity | Aug 19, 2025

Image: Freepik/DC Studio
After years of delay, Canada is finally moving forward on cybersecurity legislation. The previous Bill C-26 stalled after critics raised concerns around due process and transparency issues with sweeping ministerial powers, unclear compliance costs, and provisions that would have allowed the government to rely on “secret evidence” in court challenges.
Now a newly introduced Bill C-8 An Act Respecting Cyber Security with the controversial secret evidence clause removed and the introduction of stronger oversight, make it more acceptable to industry stakeholders and politically viable. The legislation creates a new compliance regime with enforceable standards for critical infrastructure operators, including the banking system, and introduces penalties for non-compliance. For fintechs, the implications extend well beyond checklists and into how firms manage partnerships, payments, and cross-border data.
Bill C-8 arrives alongside the Bank of Canada's supervision of payment service providers (PSPs) under the Retail Payment Activities Act on September 8, 2025. Wallets, transfer apps, and other fintech PSPs must register, meet operational requirements, and demonstrate risk and security controls. The alignment of Bill C-8 with this deadline raises the bar for cyber resilience across the fintech ecosystem.
Even if most fintechs are not directly listed under the new Critical Cyber Systems Protection Act, regulated banks and clearing systems will be. These institutions will port obligations onto their fintech partners through contracts, audits, and certifications. OSFI’s Guideline B-13 on technology and cyber risk requires federally regulated institutions to govern third-party risks, test resilience, and maintain continuous monitoring, so we can expect those same requirements to flow into fintech vendor and partner assessments.
Payments Canada has also emphasized that national systems such as Lynx are critical infrastructure requiring robust cyber resilience. For fintechs integrated with those rails, resilience is no longer optional. It has become a business differentiator that impacts customer trust and competitive positioning.
Policy analysis suggests that Bill C-8 could influence EU–Canada data adequacy assessments, critical for fintechs handling European customer data or operating cross-border platforms. A compliance strategy that includes strong governance and privacy readiness will put Canadian fintechs in a better position to scale globally. For fintechs, compliance is only the minimum floor. Continues monitoring and governance should be the program.
Bill C-8 is a structural change in how Canada is approaching digital security. For fintechs, it means cyber readiness is inseparable from growth, compliance, and trust.
Those that move early to align with the expectations of both regulators and banking partners will not only meet compliance demands, but also stand out in a crowded marketplace. Canada’s fintech sector has an opportunity to turn these new rules into a foundation for competitive strength in a global digital economy.
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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