Federal Financial Institutions Legislative And Regulatory Reporter - October 2025

Since the threats of new and increased U.S tariffs first emerged in the spring, the Ontario government has looked to reduce trade barriers and improve harmonization for licensing standards between provinces.

The 2026 Federal Budget (“Budget 2026”) proposes to grow the Canadian financial services sector, while introducing multiple checks on possible risks raised by new bank entrants and innovative technology. It also builds out existing policy measures to support digital innovation and combat fraud. There are various other measures that may be of interest to financial service providers in banking, insurance and payments.

Expanding a payment business into Canada requires navigating FINTRAC's Money Services Business registration framework. Understanding the regulatory requirements, compliance obligations, and practical steps for MSB registration helps international payment providers establish compliant operations in one of the world's most established financial markets.

The Office of the Superintendent of Financial Institutions (OSFI) published its third quarterly release of the year on September 10, 2026, noting that the targeted adjustments made to its guidance were made with a view to supporting a resilient and competitive Canadian financial system.

The Bank of Canada (the “Bank”) has published two proposed guidelines relating to the accreditation process for prospective participants under the Consumer-Driven Banking Framework: the Participating entity accreditation application requirements under the Consumer-Driven Banking Act (the “Participating Entity Guideline”) and the Third-party service provider accreditation application requirements under the Consumer-Driven Banking Act (the “TPSP Guideline”).

The Canadian Investment Regulatory Organization’s (CIRO) proposed Incorporated Approved Person model could materially change how client-facing advisors structure their businesses and receive compensation with significant impacts to sponsoring firms. The proposed rule amendments, published on July 9, 2026, would introduce a harmonized incorporated compensation option for client-facing Approved Persons across CIRO regulated dealers. Comments are due November 6, 2026.

Bill C-12 has fundamentally transformed Canada's anti-money laundering framework by introducing penalties up to forty times higher than previous levels and expanding compliance obligations across the financial sector. The legislation now requires all reporting entities to enroll with FINTRAC and maintain "reasonably designed, risk-based and effective" compliance programs, while imposing cumulative maximum penalties that can reach 3% of global revenue.

On October 13, 2026, British Columbia’s new Mortgage Services Act, S.B.C. 2022, c. 27 (the “MSA”) will come into force and effect, replacing the longstanding Mortgage Brokers Act, R.S.B.C. ch. 313 (the “MBA”). The MSA introduces a modernized regulatory framework for mortgage service providers, including expanded licensing requirements, increased disclosure obligations, enhanced enforcement tools, and significantly higher penalties for non-compliance.

This Bulletin summarizes key regulatory developments impacting the payments sector in 2025 and looks ahead to 2026.

Following a consultation period with consumer groups and the banks, the federal government has amended the Financial Consumer Protection Framework Regulations under the Bank Act (the Amendments)...

On March 5, 2025, Canada published a Final State of PFAS Report finding that the entire class of per- and polyfluoroalkyl substances (PFAS)...

The United States has escalated its trade dispute with Canada by imposing import bans on alcoholic beverages, dairy products, and motorcycles under Section 338 of the Tariff Act of 1930, while Canada responds with matched counter-tariffs on $27.6 billion worth of U.S. goods. Following the collapse of bilateral negotiations in August 2026, both nations have entered an unprecedented phase of trade restrictions that extends beyond traditional tariffs to include procurement exclusions and threatens further auto

A major U.S. vendor agreement has established a rigorous new AI safety standard for educational technology, prohibiting the use of student data for AI training and enforcing strict data minimization. While the standard does not directly bind vendors in Canada, Canadian school boards can leverage this precedent to demand equivalent contractual protections and strengthen their own AI governance frameworks.

The Supreme Court of Canada held its second annual ceremony marking the opening of the judicial year at its temporary home in the West Memorial Building, with Chief Justice highlighting the Court's increased caseload and architectural features. What significant constitutional and legal challenges will the Court address in its fall 2026 session, including cases on firearm regulations, Crown immunity, and vicarious liability?

The Canadian Investment Regulatory Organization’s (CIRO) proposed Incorporated Approved Person model could materially change how client-facing advisors structure their businesses and receive compensation with significant impacts to sponsoring firms. The proposed rule amendments, published on July 9, 2026, would introduce a harmonized incorporated compensation option for client-facing Approved Persons across CIRO regulated dealers. Comments are due November 6, 2026.

On July 2, 2026, the Canada Revenue Agency (CRA) published its updated Guidance on the Common Reporting Standard (Updated CRS Guidance).

The Government of British Columbia has published the Restricted Insurance Agent Licence Regulation, introducing a new restricted licensing framework...

In June 2022, Health Canada introduced new nutrition labelling regulations for prepackaged foods. A key feature of these regulations is the mandatory use of a front-of-package (FOP) nutrition symbol...

​The amendments to the Contaminated Sites Regulation, which take effect November 1st, 2017, will incorporate new soil, water, and vapour standards.

Since April 1, 2021, residential projects of at least 450 m² (about 5 units or more) in Montréal have been subject to the By-law for a Diverse Metropolis (the BDM).