Running a crypto exchange in Canada isn’t just about building a website and listing Bitcoin. If you’re trying to serve Canadian users, you’re stepping into one of the strictest, most detailed regulatory systems in the world. And it’s not optional. If you’re operating without a license, you’re breaking the law - and regulators are actively shutting down unregistered platforms.
Who Needs a License?
Any company that lets Canadians buy, sell, or trade cryptocurrencies needs to register with FINTRAC. That includes foreign exchanges too. If you’re based in the U.S., Singapore, or anywhere else but serve Canadian customers, you still need to register as a Foreign Money Services Business (FMSB). There’s no loophole for "just a few Canadian users." Once you have even one Canadian client, the rules apply.Domestic exchanges - those incorporated in Canada - must register as a Money Services Business (MSB). Both MSB and FMSB follow the same rules. The only difference is where the company is legally based. Either way, you’re subject to the same compliance burden.
The Core Requirements
Getting licensed isn’t a form you fill out in an hour. It’s a full-year project with multiple moving parts. Here’s what you absolutely need:- A legal entity in Canada (for MSB) or clear Canadian business ties (for FMSB)
- A designated Compliance Officer - this person must be available, accountable, and trained. They can’t be a figurehead. FINTRAC will interview them.
- Full AML/CFT policies - written, detailed, and actively enforced. This includes how you screen customers, flag suspicious activity, and report it.
- Know Your Customer (KYC) procedures - you must verify every user’s identity with government-issued ID and proof of address. Facial recognition and document authenticity checks are now standard.
- Transaction monitoring software - automated systems that flag unusual patterns, like sudden large deposits from new users or rapid trading between wallets.
- Record keeping - all transaction data, customer communications, and verification documents must be stored for at least five years.
- Cybersecurity controls - cold storage for 95%+ of assets, multi-signature wallets, penetration testing reports, and a documented incident response plan.
These aren’t suggestions. They’re mandatory. FINTRAC can and does audit exchanges. If you’re missing even one piece, your application gets rejected - or worse, you get fined after operating illegally.
What If You Trade Tokens That Are Securities?
This is where things get complicated. Not all crypto is treated the same. If your exchange lists tokens that the Canadian Securities Administrators (CSA) classify as securities - like many utility tokens, staking tokens, or tokens sold in ICOs - you need a second license.You can’t just register with FINTRAC and call it done. You also need to apply to the CSA as either an investment dealer or a marketplace operator. This means additional compliance: financial reporting, custody rules, and restrictions on how you handle customer assets.
Since February 2023, the CSA made it even harder. Platforms now need to submit a Pre-Registration Undertaking (PRU) with strict conditions:
- No pledging or lending customer crypto assets
- Separate custody accounts for each user’s holdings
- Monthly financial disclosures
- Written consent from the CSA before offering any stablecoin trading
Only a handful of exchanges - like Coinsquare and Bitbuy - made it through. Most global platforms either pulled out of Canada or got stuck in limbo. If you’re trying to list tokens like UNI, AAVE, or SOL, you need legal advice before you even launch.
Stablecoins Are a Separate Beast
Stablecoins like USDT or USDC aren’t treated like regular crypto. The CSA introduced an interim framework in October 2023 that demands:- Proof that the stablecoin issuer holds 1:1 reserves in cash or short-term government bonds
- Monthly audits by a Big Four accounting firm
- Clear disclosures to users that the stablecoin isn’t guaranteed by the Canadian government
- Separate segregation of stablecoin deposits from other customer funds
That’s why most stablecoin trading on Canadian exchanges is either limited or completely blocked unless the platform has explicit CSA approval. Even then, trading volume is capped until the issuer passes a full audit.
Costs and Timelines
Don’t underestimate the price tag. The average cost to get licensed is between CAD $50,000 and $200,000 just for legal help, compliance setup, and application filing. That’s before you buy software, hire staff, or upgrade your infrastructure.Annual ongoing costs? At least CAD $100,000 for small exchanges. For a mid-sized platform with thousands of users, it’s closer to CAD $500,000 - mostly for compliance staff, audits, monitoring tools, and legal updates.
The timeline? Six to twelve months from submission to approval - if everything’s perfect. Most applications get rejected on the first try. Common reasons: incomplete KYC procedures, vague AML policies, or a Compliance Officer with no real authority.
Who’s Still Operating in Canada?
Before 2023, over 40 crypto exchanges served Canadian users. Today, only about 15 to 20 are fully licensed. The big names are:- Coinsquare
- Bitbuy
- Newton
- NDAX
- Crypto.com (licensed under FMSB)
- Kraken (licensed under FMSB)
Most others - including well-known global platforms - either shut down their Canadian operations or stopped accepting new users. The market has consolidated. Smaller exchanges can’t afford the compliance costs. Only well-funded players survive.
What’s Coming Next?
Regulators aren’t slowing down. By 2025, Canada is expected to require:- Real-time reporting of cross-border crypto transactions over $10,000
- Reserve transparency rules for all stablecoins, similar to the U.S. and EU
- Clear rules for DeFi protocols and NFT marketplaces - even if they’re decentralized
There’s also talk of a national crypto license that would combine FINTRAC and CSA oversight into one application. That could simplify things - but only if you’re ready to meet the highest standard from day one.
What Should You Do?
If you’re building a crypto exchange for Canada:- Get legal counsel who specializes in Canadian financial regulation - not just crypto lawyers. You need someone who understands securities law and MSB rules.
- Start compliance work at least 12 months before launch. Build your KYC system, hire your Compliance Officer, and document every process.
- Don’t assume your offshore platform works in Canada. You’ll get blocked.
- Don’t list securities without CSA approval. You’ll be shut down.
- Don’t offer stablecoins without written consent. It’s not worth the risk.
Canada isn’t trying to kill crypto. It’s trying to make it safe. The rules are tough, but they’ve created a level playing field. Legitimate businesses thrive here because customers trust them. The ones that skip compliance? They disappear.
Can a U.S.-based crypto exchange legally serve Canadian customers?
Yes, but only if it registers as a Foreign Money Services Business (FMSB) with FINTRAC. The exchange must comply with the same AML/CFT rules as Canadian-based companies, including KYC, transaction monitoring, and reporting. Simply having Canadian users without registration is illegal.
How long does it take to get a crypto exchange license in Canada?
The process typically takes 6 to 12 months from submission to approval. Most applications are rejected on the first try due to incomplete documentation or weak compliance policies. Building the required systems - like KYC and transaction monitoring - often takes 6-9 months before you even submit the application.
Do I need a separate license if I trade stablecoins in Canada?
Yes. Trading stablecoins like USDT or USDC requires written consent from the Canadian Securities Administrators (CSA). You must prove the issuer holds 1:1 reserves, submit monthly audits, and segregate customer deposits. Without this approval, offering stablecoin trading is prohibited.
What happens if I operate without a license in Canada?
You risk being shut down by FINTRAC or the CSA, fined up to $500,000, and potentially facing criminal charges. Regulators have already blocked dozens of unlicensed platforms and frozen assets. Your Canadian users’ funds could be seized, and your reputation destroyed.
Can I use a third-party KYC provider to meet Canadian requirements?
Yes, but you’re still responsible for compliance. Using a provider like Jumio or Onfido helps, but you must ensure the system meets FINTRAC’s standards: government ID verification, address proof, facial matching, and fraud detection. You also need to retain records and monitor for anomalies - the provider doesn’t take legal responsibility for you.
Are DeFi platforms regulated in Canada?
Currently, there’s no formal rule for DeFi, but regulators are working on guidance expected by 2025. If a DeFi platform acts like a financial intermediary - offering lending, staking, or trading services to Canadians - it will likely need to register as an MSB or investment dealer. Ignoring this could lead to future enforcement actions.
