Americas/CA/Comparables
Canada
CSA / CIRO / OSC as example principal regulator
Canada regulated the contract with the platform, not the token issuance. CSA staff notices 21-327 through 21-333 plus CIRO membership turn a crypto-asset trading platform into an investment dealer (or a restricted dealer on the way there). There is no Form NOR. There is a decision document with terms and conditions.
Model
CTP = dealer
PRUs
Closed 2024
Custody
CIRO 2026
Similar regulation
The statute book
Primary instruments, with the RCA job each one actually does. Links open the official text.
- In force
The public list — analogue to a CASP register, not to Form 1-CRYPTO
- In force
The Howey-adjacent theory: the user’s claim on the platform is the security/derivative
- In force
Custody — a chapter RCA does not write
Translation
Rule 100–500 map
| RCA | Peer | Fit | Desk |
|---|---|---|---|
| Rule 100 CIC | Crypto Contract with the CTP (CSA 21-327) | Inverse | Canada often locates the security in the platform relationship, not in a Howey wrapping around a token. |
| Rule 200 / 300 | No issuer offering exemption for utility tokens | No analogue | Issuance is still ordinary securities law if the token is a security. |
| Intermediary | Investment dealer / restricted dealer + CIRO | Stricter | Heavier than a MiCA CASP in some custody respects; CIPF on cash at full dealers. |
| Rule 400 | None | No analogue | No deemed-cessation of the investment contract. |
Analysis
What the file is
The Canadian Securities Administrators treated the user’s contractual claim against a crypto-asset trading platform as a security or derivative (Staff Notice 21-327) and then built a registration path: terms-and-conditions decisions, a now-closed pre-registration-undertaking window, restricted-dealer status, and a push into full CIRO investment-dealer membership. Coinbase, Kraken and Crypto.com took the restricted-dealer road. Others left. New platforms apply to CIRO directly.
Why this is not an RCA analogue
RCA is for issuers of CICs. Canada’s live crypto file is for platforms. A Canadian public issuance of a token that is a security still goes through a prospectus, an offering memorandum, or a prospectus exemption — not through a NOR. If your token is not a security under Canadian law, CSA 21-327 may still catch the platform that sells it to Canadians. Geo-blocking and dealer registration are the operational facts, not a white paper.
Research
The record
- OSC list of registered CTPs (8 September 2026) is the primary public evidence of who may offer crypto products to Ontario investors.
- CIRO’s February 2026 Digital Asset Custody Framework is tiered and imposed through membership terms. It is the Canada analogue to MiCA Title V custody, not to Rule 103.
- Value-referenced crypto assets (stablecoins) have their own CSA staff notice (21-333) conditions for trading with clients — a product filter on the platform, not an issuer licence.
Ideation
What to file
- Cross-border: a Rule 300 general solicitation that reaches Ontario is a CTP/dealer problem. Put the geo-block exhibit in the SEC letter if you claim US-only distribution.
- Do not ask the Commission to register platforms inside 33-11434. Point at Canada as proof that the intermediary file can be built from existing dealer law — and that it is a different paper.
Analysis
What the file is
The Canadian Securities Administrators treated the user’s contractual claim against a crypto-asset trading platform as a security or derivative (Staff Notice 21-327) and then built a registration path: terms-and-conditions decisions, a now-closed pre-registration-undertaking window, restricted-dealer status, and a push into full CIRO investment-dealer membership. Coinbase, Kraken and Crypto.com took the restricted-dealer road. Others left. New platforms apply to CIRO directly.
Why this is not an RCA analogue
RCA is for issuers of CICs. Canada’s live crypto file is for platforms. A Canadian public issuance of a token that is a security still goes through a prospectus, an offering memorandum, or a prospectus exemption — not through a NOR. If your token is not a security under Canadian law, CSA 21-327 may still catch the platform that sells it to Canadians. Geo-blocking and dealer registration are the operational facts, not a white paper.
Primary sources on file
CSA Staff Notice 21-327 — Guidance on the application of securities legislation to entities facilitating the trading of crypto assets
Canadian Securities Administrators/16 Jan 2020/RCA review 8 Sept 2026
Primary regulatory
OSC — registered crypto-asset trading platforms
Ontario Securities Commission/8 Sept 2026/RCA review 8 Sept 2026
Primary regulatory
CIRO Digital Asset Custody Framework
Canadian Investment Regulatory Organization/3 Feb 2026/RCA review 8 Sept 2026
Primary regulatory
RCA publishes source-linked intelligence for professionals. Nothing here is a token-buying call, a legal opinion, or an “approved / safe / regulated” badge. Every material claim is dated. Incomplete files stay incomplete.