Exhibit 8.2

April 17, 2026

 

Royal Bank of Canada

200 Bay Street

Royal Bank Plaza

Toronto, ON M5J 2J5

 

Norton Rose Fulbright Canada llp
222 Bay Street, Suite 3000, P.O. Box 53
Toronto, Ontario  M5K 1E7 Canada

 

Dear Sirs/Mesdames:

 

 

F: +1 416.216.3930

nortonrosefulbright.com

Senior Global Medium-Term Notes, Series J

 

We have acted as Canadian tax counsel to Royal Bank of Canada (RBC) in connection with the issuance by RBC of its Senior Global Medium-Term Notes, Series J – U.S. $1,500,000,000 aggregate principal amount of 4.400% Senior Fixed Rate/Floating Rate Notes due April 17, 2030 and U.S. $1,500,000,000 aggregate principal amount of 4.612% Senior Fixed Rate/Floating Rate Notes due May 3, 2032 (collectively, the Offered Securities).

 

We hereby confirm to you that the statements of Canadian tax law set forth under the heading "Canadian Federal Income Tax Considerations" in the pricing supplements relating to the Offered Securities, each dated April 14, 2026, are our opinion and are accurate in all material respects subject to the limitations and qualifications therein.

 

We hereby consent to the filing of this opinion as an exhibit to RBC’s Report of Foreign Private Issuer on Form 6-K and to the reference to us under the heading "Canadian Federal Income Tax Considerations" in the pricing supplements referred to above. In giving such consent, we do not thereby admit that we are in the category of persons whose consent is required under Section 7 of the Securities Act of 1933, as amended.

 

Yours truly,

 

“Norton Rose Fulbright Canada LLP”