Budget Implementation Act: Financial Services Highlights

On March 26, 2026, the Budget 2025 Implementation Act, No. 1 (Budget Implementation Act) received royal assent. The Budget Implementation Act introduces a significant number of new measures impacting the regulation of financial services in Canada.

Introduced in November 2025 as Bill C-15, the Budget Implementation Act aims to build a stronger Canadian economy and strengthen Canada’s financial sector, while also making the sector work better for consumers. The key new measures enacted as part of the Budget Implementation Act include the new Stablecoin Act, the revised final legislative framework for open banking in Canada, a new fraud risk management framework for banks and several key measures governing prudential regulation of federal financial institutions.

Stablecoins

The Budget Implementation Act also enacts the Stablecoin Act, a new federal regulatory framework in Canada to regulate issuers of fiat-backed stablecoins. The new legislation will be overseen by the Bank of Canada and, notably, will apply only to non-financial institution issuers. Federal, provincial and foreign financial institutions that are prudentially regulated will be outside the scope of the regime, which differs from the stablecoin regime in some other jurisdictions. Non-financial institution issuers of stablecoins will be required to register with the Bank of Canada and comply with a comprehensive set of requirements governing reserve obligations, restrictions on interest and yield payments, redemption of stablecoins, and requirements in respect of developing and making public key compliance policies. Regulations implementing the Stablecoin Act remain pending.

Open Banking

The Budget Implementation Act enacts the amended Consumer-Driven Banking Act, which will enable individuals and businesses to safely and securely share their financial data with participating entities. The Bank of Canada will oversee the open banking framework. An amendment has also been made to the Personal Information Protection and Electronic Documents Act (PIPEDA), which introduces a data mobility right that requires an organization to disclose an individual’s personal information to another organization, if requested, if both organizations are subject to a data mobility framework.

Fraud Risk Management

Through amendments to the Bank Act, the federal government has implemented a number of measures that are intended to help combat consumer-targeted fraud. Banks will be required to:

• Establish policies and procedures for detecting and preventing consumer-targeted fraud and mitigating its impacts
• Collect and report data on consumer-targeted fraud to the Financial Consumer Agency of Canada by way of an annual report
• Obtain express consent from consumers before the activation of certain capabilities for a personal deposit account, and permit a consumer to deactivate certain account capabilities
• Permit a consumer to adjust maximum transaction limits

Prudential Regulation

In addition, the Budget Implementation Act introduces the following changes to federal financial institutions legislation, which are intended to support the competitiveness of small- and medium-sized financial institutions:

• Public float requirement: The equity threshold under the federal financial institutions legislation that requires banks, insurance companies and trust and loan companies to maintain a 35% public holding requirement has been raised from C$2-billion to C$4-billion.
• Federal credit unions: Several new measures have been introduced to the Bank Act to simplify the transition of provincial credit unions to the federal credit union framework. The new measures include eliminating the membership vote requirement for federal credit unions when amalgamating with smaller provincial credit unions that continue federally, facilitating asset transactions with provincial credit unions, and permitting transitional relief from the federal market conduct rules in connection with federal continuances.
• Repeal of commercial lending and portfolio limits: The Budget Implementation Act repeals the commercial lending limit applicable to insurance companies and trust and loan companies and introduces a new provision that permits the Superintendent to make an order directing the reduction of commercial loans. Similar changes are made in respect of the real property, equities and portfolio limits in federal financial institution statutes.
• Notice-and-access: The federal financial institutions legislation is also amended to allow for the electronic delivery of governance documents to shareholders, members and policyholders without their consent, while retaining the right to request paper copies, mirroring the Canada Business Corporations Act, which will be a welcome change for many.
• In addition, the “Sunset Provisions” in the federal financial institution legislation have been amended from June 2026 to June 2033.

For more information, please contact the authors or any other member of our Financial Services Regulatory group.