There is a broad range of banking and financial service activities that require licensing or registration in Canada, either at the federal or provincial level, including the following:

• Accepting deposits
• Carrying on insurance business (life, property and casualty, etc.), including acting as an insurer, underwriter, agent or broker, claims adjuster
• Providing investment, fund management and financial advice and engaging in investment management activities
• Trading and distributing securities, derivatives and other investments, including as a broker dealer or marketplace
• Dealing in, trading in, and administering mortgages and mortgage lending, including acting as a mortgage agent, broker, administrator or lender
• Providing money services, including dealing in foreign exchange; transferring funds from one individual or organization to another using an electronic funds transfer network or any other method; and cashing or selling money orders, traveler’s checks or anything similar and dealing in virtual currencies
• Engaging in retail payment activities
• Providing payday loans as a lender or broker
• Providing credit reports
• Collecting debts on behalf of another

In Canada, many crypto-assets qualify as securities (in particular, investment contracts) on the basis of their characteristics. The test for investment contracts developed by case law is the Pacific Coin test (modeled after the Howey test in the United States). However, irrespective of the characterization of a particular crypto-asset, if a crypto-asset trading platform or service (CTP) custodies that crypto-asset for Canadian clients, the CTP will still need to obtain registration as a dealer in securities in Canada because it will be deemed to be dealing in crypto contracts.

Staff Notice 21-327 Guidance on the Application of Securities Legislation to Entities Facilitating the Trading of Crypto Assets sets out the CSA's position in regards to platforms that facilitate trades in crypto-assets. They will be subject to securities laws, notwithstanding whether or not those platforms trade assets that are in fact “securities.” Regulators in Canada require CTPs to seek registration as restricted dealers in securities, subject to bespoke terms and conditions.

Subsequently, the CSA published Staff Notice 21-332 Crypto Asset Trading Platforms: Pre-Registration Undertakings - Changes to Enhance Canadian Investor Protection, which imposes investor protection requirements on CTPs both pre- and post-registration in the form of pre-registration undertakings. The notice also contemplated that CTPs could obtain consent with respect to trading, on an interim basis, certain stablecoins, referred to by the CSA as "value referenced crypto assets" (VRCAs). In October 2023, the CSA published Staff Notice 21-333 Crypto Asset Trading Platforms: Pre-Registration Undertakings – Changes to Enhance to provide further developed terms and conditions for CTPs that permit trading in VRCAs. CTPs are required to comply with the imposed additional requirements for prescribed disclosures, disclaimers in marketing materials, and updated know-your-product policies and procedures. The deadline for compliance was extended to 31 October 2024.