Canada regulator says tokenized deposits have same legal status as traditional bank deposits

Canada's Office of the Superintendent of Financial Institutions (OSFI) announced on September 10, 2026, that tokenized deposits are legally equivalent to traditional bank deposits. Under a technology-neutral approach, OSFI's 2027 capital guidelines place qualifying tokenized deposits in Group 1a, granting them bank-like credit-risk treatment. However, banks must keep these assets redeemable at par and legally binding, while continuing to comply with existing cyber-risk and third-party guidelines.

Tokenized deposit legal equivalence

• ▪Canada's Office of the Superintendent of Financial Institutions declared on September 10, 2026, that tokenized deposits are legally equivalent to traditional bank deposits.
• ▪The Office of the Superintendent of Financial Institutions stated that the underlying technology of a financial product does not determine its legal character.

Capital treatment under 2027 rules

• ▪To qualify for bank-like treatment under the 2027 rules, tokenized deposits must remain legally binding, redeemable in fiat at par, and tied to the issuing bank's creditworthiness.
• ▪The Office of the Superintendent of Financial Institutions can impose stricter liquidity treatment if wallet providers, blockchain operators, or redemption structures introduce added risks.
• ▪Under the 2027 crypto-asset capital and liquidity guideline finalized on September 10, 2026, qualifying tokenized deposits fall into Group 1a and receive the same credit-risk treatment as traditional deposits.

Technology-neutral regulatory approach

• ▪The technology-neutral approach distinguishes tokenized deposits, which are direct claims on the issuing bank, from stablecoins, which may depend on separate reserve assets.
• ▪Federally regulated financial institutions must continue to comply with existing laws and regulations, including technology and cyber-risk guideline B-13 and third-party risk guideline B-10.

Existing compliance obligations apply

• ▪Financial institutions remain responsible for ensuring compliance with applicable regulations even when third-party companies perform activities on their behalf.
• ▪The Office of the Superintendent of Financial Institutions expects financial institutions to consult their lead supervisors before introducing novel or unusual products or services.