Crypto Custody Compliance: CIRO’s New Framework

On February 3, 2026, the Canadian Investment Regulatory Organization (“CIRO”) published a Notice on CIRO’s Digital Asset Custody Framework (the “Notice”) setting out updated terms and conditions (the “New Framework”) for the custody of digital assets by Dealer Members (as defined by the Investment Dealer and Partially Consolidated Rules, the “CIRO Rules”), including those operating crypto-asset trading platforms (“CTPs”) in Canada.

Background

In Canada, a firm that facilitates the trading of either: (a) crypto assets that are securities and/or derivatives or (b) instruments or contracts, based on crypto assets, that are securities or derivatives, are required to seek registration as an investment dealer and membership as a Dealer Member with CIRO (such firms referred to by CIRO and the Canadian Securities Administrators (the “CSA”) as CTPs). However, the CIRO Rules, which govern the activities of investment dealers, were designed to govern traditional securities and derivatives, and