The Canadian Securities Administrators (CSA) have introduced a structured pathway for unregistered crypto asset trading platforms (CTPs) to continue operating in Canada while undergoing registration review. This process centers around the enhanced pre-registration undertaking (PRU), a formal commitment by platforms to adhere to investor protection standards during the interim period before full regulatory approval.
Platforms that file a PRU are not guaranteed registration. However, by submitting this document, they signal a willingness to comply with regulatory expectations aligned with those imposed on registered entities. The PRU framework ensures greater transparency and accountability, helping safeguard Canadian investors during a period of rapid digital asset growth and evolving market risks.
Regulators have already completed reviews of several PRU filings. These reviewed undertakings represent a critical step toward formal oversight, though terms may be updated as applications progress. Additionally, final registration conditions or exemptive relief could differ from the initial PRU commitments.
Platforms with Reviewed Pre-Registration Undertakings
Below is a list of crypto asset trading platforms whose PRUs have been assessed by the CSA:
ByteX Financial Ltd. et al operating as ByteX
As a crypto asset trading platform, ByteX has submitted an enhanced PRU dated March 24, 2023. This filing reflects the platform’s commitment to meeting regulatory standards during its registration process. By adhering to the PRU, ByteX agrees to implement robust investor safeguards, including proper disclosure practices and operational transparency.
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DigiFinex Canada Limited et al operating as DigiFinex
DigiFinex, another active participant in Canada’s digital asset space, also filed its PRU on March 24, 2023. The undertaking outlines specific compliance measures related to client fund protection, cybersecurity protocols, and market integrity—key pillars in building trust within the crypto ecosystem.
Satstreet Inc.
Satstreet Inc. submitted its Pre-Registration Undertaking on March 24, 2023; however, it is important to note that this undertaking expired on May 1, 2025. The company remains unregistered and has requested a hearing regarding its registration application, which is currently under review by the Director. Investors should exercise caution when engaging with platforms in this status, as they no longer operate under active PRU protections.
Uphold Worldwide Ltd. et al operating as Uphold
Uphold filed its PRU on March 27, 2023. However, a notice of withdrawal was delivered under Section 17 of the PRU on May 29, 2025. This means Uphold has formally withdrawn from the pre-registration process and no longer operates under the terms of the undertaking. Investors should verify current regulatory status before using any trading service.
Understanding the PRU Framework
The enhanced pre-registration undertaking is more than a procedural formality—it's a binding agreement that imposes real obligations on unregistered platforms. These include:
- Segregation of client assets to protect user funds
- Implementation of robust cybersecurity frameworks
- Transparent fee structures and risk disclosures
- Compliance with anti-money laundering (AML) and know-your-customer (KYC) regulations
- Regular reporting to regulators
These requirements mirror those expected of fully registered firms, ensuring that even platforms in transition uphold high operational standards.
It's crucial to understand that filing a PRU does not equate to regulatory approval. It simply allows eligible platforms to continue serving Canadian users under strict conditions while their applications are evaluated. The final decision rests with provincial securities commissions, which assess each application based on compliance readiness, financial stability, and governance practices.
Investor Guidance and Risk Awareness
The CSA emphasizes that crypto asset trading involves significant risk and may not be suitable for all investors—especially retail participants. Key concerns include:
- Extreme price volatility affecting asset value
- Limited liquidity in certain markets
- Potential for fraud or technical failures
- Lack of insurance or compensation mechanisms for lost funds
Before investing, individuals are strongly encouraged to:
- Consult the official list of registered crypto trading platforms
- Educate themselves on blockchain technology and digital asset fundamentals
- Evaluate their risk tolerance and investment goals
While regulatory oversight through mechanisms like the PRU improves investor protection, it cannot eliminate all risks inherent in crypto trading.
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Frequently Asked Questions (FAQ)
What is a Pre-Registration Undertaking (PRU)?
A PRU is a formal commitment made by an unregistered crypto asset trading platform to follow specific investor protection rules while applying for regulatory registration in Canada. It enables continued operations under supervised conditions.
Does filing a PRU mean a platform is regulated?
No. Filing a PRU does not grant regulatory approval. It indicates the platform is working toward compliance but remains under review. True regulation occurs only after official registration.
Why did Satstreet’s PRU expire?
Satstreet Inc.’s Pre-Registration Undertaking expired on May 1, 2025, because the company did not meet ongoing requirements or extend its agreement. It is currently unregistered and seeking a hearing on its application.
Can I trust a platform with an active PRU?
Platforms with active PRUs have made enforceable commitments to investor protection. While this increases confidence, investors should still conduct due diligence and recognize that risks remain.
What happens if a platform withdraws its PRU?
If a platform withdraws its PRU—like Uphold did on May 29, 2025—it is no longer bound by the interim regulatory framework. Users should reassess the platform’s legitimacy and consider moving assets if necessary.
How can I check if a crypto platform is registered in Canada?
Visit the Canadian Securities Administrators’ official website or consult individual provincial securities commission databases to verify a platform’s registration status.
Staying Informed in a Changing Landscape
As Canada refines its approach to digital asset regulation, tools like the enhanced PRU help bridge the gap between innovation and investor safety. The goal is clear: foster responsible growth in the crypto sector while minimizing harm to consumers.
For traders and investors, staying informed is non-negotiable. Whether evaluating platforms with active PRUs or monitoring registration updates, knowledge remains the best defense against risk.
👉 Stay ahead with insights into compliant crypto trading environments and global regulatory trends.
Last updated: June 25, 2025
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