une main qui tient une guitare

Article

Everything you need to know about the Canadian Investment Regulatory Organization (CIRO): a dynamic resource

Nous sommes désolés. Le contenu de cette page n'est présentement disponible qu'en anglais.

Nous sommes désolés. Le contenu de cette page n'est présentement disponible qu'en anglais.

Welcome to BLG and BLG Beyond AUM Law’s dynamic resource on the Canadian Investment Regulatory Organization (CIRO). We invite you to bookmark and revisit this page which will be updated to reflect developments of importance to CIRO registered firms. Resulting from the amalgamation of the Investment Industry Regulatory Organization of Canada (IIROC) and the Mutual Fund Dealers Association of Canada (MFDA), CIRO has been operating since January 1, 2023 and has led to – and will continue to generate – significant changes in the registration and oversight of investment and mutual fund dealers across Canada, as well as new opportunities. This resource is designed to help you find, understand and act on CIRO-related topics, such as new developments, rules, registration requirements, enforcement and examinations and more.

Recent developments

  • August 27, 2026 – The CSA and CIRO published Joint Staff Notice 91-307 Guidance related to Event Contracts: Compliance with Regulatory Requirements (the Staff Notice). While event contracts—defined as products whose settlement is based on the outcome of an underlying future occurrence or event—may fall within the definition of a security or derivative under applicable legislation, the CSA has concluded that event contracts based on sports or entertainment events or outcomes should not be regulated under such legislation. In addition, CIRO staff do not consider it appropriate to approve applications by dealer members to trade in these event contracts. The Staff Notice indicates that further guidance on other types of event contracts will follow.
  • July 30, 2026 – CIRO published a proposed new crypto fee model designed to recover crypto trading platform (CTP) surveillance regulatory costs through an activity-based approach (Crypto Fee Model). Currently, CIRO utilizes fixed fees to recover CTP oversight costs, which will continue in the interim until the effective date of the proposed new model. The new activity-based Crypto Fee Model is proposed to become effective on July 1, 2027. From July 1, 2027, to March 31, 2028, cost recovery will be based on direct costs only, while from April 1, 2028, onwards, CIRO will transition to full cost recovery. The Crypto Fee Model separates Members into three levels based on their surveillance requirements and allocates costs using a two-step process: first, surveillance costs are distributed across the three levels based on supervisory effort and then secondly, allocated to individual Members based on trading activity. Additionally, all Members are subject to an annual minimum fee of either $50,000 or $100,000 based on their level. Comments on the proposal are due by September 28, 2026.
  • July 29, 2026 – CIRO, jointly with the CSA, published guidance on marketing and sales of exchange-traded funds (ETFs) that are listed on a foreign exchange but are not also on a Canadian exchange (Foreign ETF(s)). Joint Staff Notice 81-339 Industry Practices Relating to Foreign-Listed Exchange-Traded Funds (Staff Notice) reminds managers of Foreign ETFs that active marketing or promotion of a Foreign ETF in Canada could trigger the prospectus requirement and, in Ontario, Quebec and Newfoundland and Labrador, the investment fund manager (IFM) registration requirement. Specifically, the Staff Notice notes that if a party takes an active step to market or promote the sale of the securities of a Foreign ETF in Canada, that this activity could be an act in furtherance of a sale of securities, and therefore a distribution in Canada, triggering the requirement to file a prospectus. The Staff Notice provides examples of active steps that may indicate a distribution of securities and how these same steps may trigger the requirement to register as an IFM in those jurisdictions. It also clarifies how business conduct requirements that are applicable to registered dealers and their registered representatives apply to Foreign ETFs, including Know Your Product, Know Your Client and suitability obligations. The Staff Notice also encourages order execution-only dealers to play a more active role in notifying investors on the key differences between investing in a Foreign ETF and an ETF listed on a Canadian exchange (Canadian ETF(s)). A summary on the key differences between Foreign and Canadian ETFs, such as the differences in regulatory frameworks that each are subject to, tax and foreign currency considerations, are set out in the Staff Notice.

Key Contacts