Stablecoins and tokenized deposits are poised to transform the Canadian payments ecosystem. Both instruments promise faster, cheaper, and programmable payments; however, they differ in their structure, who issues them, how they can be used, and what legal protections they carry. As Canada moves to implement these instruments, financial institutions and fintechs need to understand the distinctions.
The Department of Finance Canada is currently developing the regulations for the Stablecoin Act (Canada) and has indicated that it expects the stablecoin framework to come into force in 2027. Meanwhile, in a nod to financial institutions and their efforts to introduce tokenized deposits, the Office of the Superintendent of Financial Institutions (OSFI) released a statement on September 10 affirming its support for innovation and competition within Canada’s financial system, and inviting financial institutions to engage with OSFI in advance of launching any novel products or services, and to seek legal advice as appropriate.
The structural features between stablecoins and tokenized deposits drive divergent use cases.
The Canadian Stablecoin Act applies to licensed entities that are not “financial institutions” as defined in the Bank Act (Canada)1. A stablecoin under that Stablecoin Act is defined as a digital asset that is designed to maintain a stable value relative to the value of one fiat currency, backed 1:1 by high-quality liquid assets, and that cannot pay interest/yield. For a more detailed overview of the Stablecoin Act, please see our bulletin.
On the other hand, a tokenized deposit is a digital representation of a customer deposit on a bank’s balance sheet, typically issued on a permissioned ledger, which may be eligible for deposit insurance (if structured appropriately), and is permitted to pay interest.
Stablecoins live in the open, whereas tokenized deposits live inside the banking system.
The following table summarizes the structural differences:
|
Fiat-backed stablecoins |
Tokenized deposits |
|
|
Reserve requirement |
At least 1:1 reserve requirement of high-quality liquid assets |
No reserve requirement, and backed by a financial institution’s deposit liabilities (fractionalized and no separate reserve funds) |
|
Issuer |
Non-financial institution issuers under Stablecoin Act legislation |
Banks and other deposit-taking financial institutions |
|
Deposit insurance |
Not covered |
May be covered (if structured appropriately) |
|
Interest/yield |
Not permitted by Stablecoin Act legislation |
Permitted |
|
Compatibility |
Interoperable across decentralized applications and wallets |
Typically confined to the banking ecosystem |
Stablecoins are preferred where cross-border capabilities, financial inclusion, and accessibility matter most. Accordingly, their primary use cases include the following:
Tokenized deposits are preferred where institutional trust (i.e., trusted third-party intermediation), yield (for cash management), and deposit insurance matter most. Accordingly, their uses cases include the following:
Stablecoins and tokenized deposits share similar technology stacks that enable programmable capabilities, supporting automation via smart contracts and AI-driven agentic use cases. They also enable instant low-cost settlement among participants on networks/platforms, as evidenced by PayPal’s introduction of its USD stablecoin (which can be extended to tokenized deposits due to the shared technology stack between the two instruments). The choice between stablecoins and tokenized deposits will ultimately come down to whether holders prioritize open access or institutional trust in each case, resulting in a situation where holders will utilize both instruments, depending on the capability they seek.
Stablecoins and tokenized deposits are not substitutes of one another. They are complementary instruments serving different use cases and holder requirements within the same payments ecosystem. Institutions that understand where each instrument fits, and prepare accordingly, will be best placed as these frameworks move toward implementation.