Canada OSFI rules tokenized deposits legally same as traditional bank deposits

Canada’s banking regulator has clarified that tokenized deposits are not legally distinct from traditional bank deposits, giving federally regulated financial institutions a clearer runway to build deposit products on blockchain and other digital infrastructure. The statement from the Office of the Superintendent of Financial Institutions signals that technology alone does not create a new category of financial product under Canadian federal law.

Technology-neutral by design

OSFI said financial institutions and their third-party providers have been developing new products as digital finance advances, including tokenized and other digitally represented deposits, and that its statement was intended to clarify how existing federal financial institution laws apply when banks use new technology to offer them. Under the regulator’s technology-neutral approach, the technology used to build or deliver a product does not determine its legal nature.

“Tokenized deposits are, for example, not legally distinct from traditional deposits,” the regulator wrote. In practice, that means a deposit does not become a separate financial product simply because it is represented digitally or runs on blockchain infrastructure. The offering institution remains responsible for meeting every law and regulation that applies to the underlying banking activity.

The clarification places the legal focus on the underlying financial claim, leaving banks free to use different technical systems as long as the product stays within their permitted activities. Institutions must ensure the products comply with applicable rules even when outside companies perform parts of the service on their behalf. OSFI pointed banks to its B-13 guideline covering technology and cyber risk management and its B-10 guideline for third-party risk management.

Banks considering novel products are expected to consult their OSFI lead supervisors before launch, and the regulator encouraged institutions to seek legal advice where appropriate.

Deposits, not stablecoins

The distinction matters because a tokenized deposit is a commercial bank deposit represented on digital ledger infrastructure and issued by the bank holding the underlying funds. The money remains a liability of the commercial bank rather than becoming a reserve-backed token issued outside the bank. Stablecoins can use similar blockchain rails but are structured differently, and their legal treatment depends on the issuer and the framework governing the asset. OSFI’s statement specifically concerns deposits issued by federally regulated institutions.

Globally, tokenized bank deposits moved well past the experiment stage during 2026. In July, Swift launched a blockchain ledger pilot with 17 banks across six continents, including HSBC, Citi, BNP Paribas, UBS, Standard Chartered, ANZ and DBS, to test tokenized deposit payments for round-the-clock cross-border settlement. That work advanced to a live transaction in August, when HSBC and Standard Chartered connected their independently operated tokenized deposit platforms through the shared ledger, which matched and netted payment obligations before settlement through existing banking systems.

Other models are also in motion. Custodia Bank and Vantage Bank unveiled a dual-purpose token in June designed to function as a bank deposit inside their Hazel banking network and become a stablecoin when transferred outside the consortium, with an Ethereum-based system operating since March ahead of a planned fourth-quarter launch. LayerZero and Keeta announced a system in July intended to make tokenized commercial bank deposits transferable across Ethereum, Solana, Base and the Keeta Network, covering nine currencies including the Canadian dollar.

Parallel stablecoin track

Canada’s treatment of tokenized deposits is developing alongside a separate regulatory process for fiat-backed stablecoins. Bank of Canada Governor Tiff Macklem said in December 2025 that stablecoins should be pegged one-to-one to central bank currency and backed by liquid government assets, with clear redemption terms, fees and timing disclosures. The 2025 federal budget included provisions for a new stablecoin framework, with the Bank of Canada expected to receive 10 million Canadian dollars over two years beginning in 2026 to administer the regime. The planned legislation would amend the Retail Payment Activities Act to cover payment service providers handling stablecoin transactions.

For Canadian banks, the OSFI statement reduces one layer of legal ambiguity that has slowed institutional blockchain projects in other jurisdictions. By anchoring tokenized deposits firmly inside the existing deposit framework, the regulator has effectively told banks that the compliance perimeter does not move when the ledger does, provided risk management, cyber security and third-party oversight keep pace.

The move aligns Canada with a broader international pattern in which supervisors distinguish between bank-issued digital money and privately issued stablecoins, treating the former as ordinary deposits and the latter as a separate asset class requiring bespoke rules. Institutions launching tokenized deposit services in Canada will still face the full weight of supervisory expectations, but they now do so with the legal classification question settled.