The deposits sit somewhere else
Up from half a million active users in early 2022, Koho's revenue run rate is past $100 million, doubled year over year, run by a team of roughly 250 people. On paper, that reads like a bank growing fast. Except, it isn't one.
Koho doesn't hold the deposits sitting in its customers' accounts, and it doesn't issue its own card. Peoples Trust, a federally regulated trust company, holds the money and carries the regulatory weight. Mastercard issues the card and runs it over its network. Koho builds the app, owns the customer relationship, and sits on top of both.
That split is the reason Koho can move as fast as it does. A Schedule 1 bank like RBC or Scotiabank answers to OSFI's full capital and governance regime on everything it does. Koho answers to it indirectly, through its partners, for the parts of the business that actually touch deposits. Everything else — the interface, the credit-building feature, the interest rate it decides to offer — it can ship on its own timeline. Renting the regulatory weight instead of carrying it is what makes 250 people and two million accounts possible.
Koho has spent since 2021 trying to become the thing it's currently renting from. It's now in the second of three phases of OSFI's bank licensing process, working toward a Schedule 1 charter of its own. If it gets there, the architecture that made this growth possible becomes the architecture it's walking away from. A full charter means Koho holds its own deposits, carries its own balance sheet, and answers to OSFI directly rather than through Peoples Trust.
Here's what that means for how the company can talk to customers, before and after. Right now, when Koho asks someone to move their whole pay-cheque over, it has no institutional weight to lean on — no century of history, no "your grandparents banked with us." The entire trust argument has to be made at the product level: the interest rate, the credit score increases, the number of people already using it. That's not a lesser form of marketing. It's the only form available to an institution that doesn't yet have a charter to point to.
The day the charter lands, that changes. An institution that spent years earning trust through visible product performance gets to add a claim it couldn't make before — federally regulated, CDIC-insured, on its own book. The temptation will be to lead with the charter, because it's the more traditional credibility signal. The harder, better call is to keep leading with the product proof that got two million people to trust an app with their pay-cheque in the first place, and let the charter sit underneath it as reassurance, not as the headline.
That call can't be made the week the charter arrives. Legal and compliance will have their own view of what can be claimed and when, and if marketing hasn't already built the messaging framework alongside them, the charter announcement gets stuck in review at the exact moment it needs to move fast. The actual work, starting now, is a joint workstream: legal defining what the new claim can say, marketing deciding how much weight it carries relative to the product proof, agreed and drafted long before the regulator's approval letter arrives.
K Baksh
Sources: Koho company disclosures via Global Recognition Awards, February 2026; The Globe and Mail, Koho financing and OSFI bank licensing coverage; Canadian Fintech 2026 industry overview.