IIROC Proposes UMIR Amendments To Address Dark Liquidity

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)...