On March 26, 2026, Bill C-15, the Budget Implementation Act 2025, received Royal Assent.[1]
The headline measure is Canada’s proposed federal framework for fiat-backed stablecoin issuers.
Less visible, but potentially more impactful from an operational standpoint, is an amendment to the Retail Payment Activities Act (RPAA). The amendment introduces a sixth payment function, drafted in technology-neutral terms, that may expand how payment activities are interpreted under the Act.
For firms operating in digital assets, payments, and custody models, this is a development that warrants close attention.
What Bill C-15 Introduces
The RPAA currently applies to entities performing one or more defined payment functions for end users. Bill C-15 introduces an additional function, described as the transmission or maintenance of an end user’s encrypted or tokenized payment instrument, or an end user’s private key.[2]
The language does not explicitly reference stablecoins. Instead, it is framed broadly and in a manner that is not tied to a specific technology or asset type.
Why This Amendment Is Being Watched Closely
Legal analysis has indicated that, depending on how this language is interpreted, the amendment may extend beyond stablecoin-related use cases.[3]
Because the provision references encrypted or tokenized payment instruments and private keys, it may, on a broad reading, capture certain custodial or key-management activities associated with digital asset business models.
This could include, depending on interpretation, custodial wallet providers, digital asset custodians, exchanges with custody functions, and key-management infrastructure providers.
However, this remains interpretive analysis. At the time of writing, the Bank of Canada has not issued formal guidance confirming how this function will be applied in practice. The final scope will depend on forthcoming regulatory clarification.
What Is In Force and What Is Not
Bill C-15 has received Royal Assent.[1]
However, both the proposed stablecoin framework and the RPAA amendment are not yet in force. They will come into force on a date to be set by order of the Governor in Council.[4]
This distinction matters.
Until that order is issued, the new payment function is not enforceable, and the regulatory perimeter remains unchanged.
At the same time, the period leading up to implementation is where operational readiness is established.
A Practical Approach for Digital Asset Firms
- ☑Map your activities. Identify where your business involves the transmission or maintenance of payment instruments or private keys. This should include custody models, wallet infrastructure, and access control mechanisms.
- ☑Familiarize yourself with the existing RPAA registration guidance. The Bank of Canada has already articulated expectations for registered payment service providers, including operational risk management, safeguarding, and incident response. Regardless of how the scope of the Act may expand, these expectations will remain as they form the foundation of the RPAA supervisory framework.
- ☑Assess operational readiness. Firms that have documented governance, custody controls, key management processes, and third-party dependencies will be better positioned than those starting from a standing start.
- ☑Monitor regulatory guidance closely. The Bank of Canada is expected to provide further clarity on how the new function will be interpreted. That guidance will ultimately define the regulatory perimeter.
- ☑Track the coming-into-force date. The Governor in Council order will determine when the new obligations apply and whether a transition period is provided.
The Broader Context
The significance of this amendment is not yet defined by regulation, but by how it may ultimately be interpreted.
What is clear is that Canadian regulatory expectations are evolving. The introduction of a stablecoin framework alongside amendments to the RPAA signals a continued move toward formal oversight of payment models that rely on digital infrastructure.
For firms operating in these spaces, the distinction between what is explicitly in scope today and what may be brought into scope tomorrow is becoming increasingly relevant.
Bottom Line
The stablecoin framework is the headline development.
The RPAA amendment is structural, and its impact will ultimately be determined through regulatory guidance.
Until that guidance is issued, the prudent approach is not to assume scope but not to dismiss it either.
Preparation at this stage is not about reacting to confirmed obligations. It is about ensuring that, should scope expand, your organization is not starting from zero.
How Tamlo and Sentinence Support This Work
Tamlo International, in strategic alliance with Sentinence, supports organizations across the full RPAA lifecycle from an organization’s initial scoping process and Bank of Canada registration application through to policy development, testing, annual program reviews, and stakeholder RPAA training.
Where required, this may include gap assessments, the design of operational risk and safeguarding frameworks, training aligned to regulatory expectations, and support in responding to regulatory inquiries.
For organizations operating in payments, remittance, and digital asset environments, early alignment with regulatory expectations can materially reduce implementation pressure as requirements are finalized. Organizations that invest early in building their frameworks are typically better positioned to adapt as regulatory expectations evolve, particularly where that work is grounded in practical experience and supported by subject matter expertise.
Organizations that engage Tamlo and Sentinence in building out their RPAA compliance and training are establishing that foundation early, positioning them to respond as RPAA requirements continue to evolve.
Reach out to mcosgrove@tamlo-rpaa.ca or angela@sentinence.com.
Sources
- Department of Finance Canada — Legislation passes to implement Budget 2025: Canada Strong (Royal Assent news release, March 26, 2026)
- Stikeman Elliott LLP — Newly Minted: Canada’s Proposed Federal Stablecoin Act (legal interpretation)
- Osler, Hoskin & Harcourt LLP — Canada releases draft framework for stablecoin regulation (legal interpretation)
- Department of Finance Canada — Canada’s Stablecoin Framework (official policy page)