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

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

  • October 8, 2025 - CIRO released a Proposed Amendment of Approved Person Fees Component within the Annual Fee of Dealer Member Fee Model, specifically increasing the Approved Person (AP) Fees Component from $250 to $300 per AP annually, effective April 1, 2026. This change is intended to recover approximately $6.5 million in incremental costs resulting from expanded registration responsibilities delegated to CIRO across multiple jurisdictions. CIRO will also cease collecting activity-based NRD fees and end cost recovery arrangements with certain provincial regulators. While the estimated overall CIRO fees to Dealer Members will increase by 5%, the impact is said to be minimal for small firms, with larger mutual fund dealers absorbing most of the increase due to their higher AP counts. Written comments on the proposal are due by November 7, 2025.

  • On October 6, 2025 – CIRO released updated guidance for Dealer Members regarding ComSet Reporting Requirements. The updated guidance applies to mutual fund dealers and investment dealers. The updated guidance specifies the supporting documentation required when filing or modifying ComSet events and also contains ComSet filing FAQs. The updated guidance is effective November 1, 2025.
  • On October 3, 2025 – The FCAA and CIRO announce effective date for authorization of registration authority to CIRO. Effective October 1, 2025, the Financial and Consumer Affairs Authority of Saskatchewan authorized CIRO to carry out certain registration functions, including the registration of investment dealers, mutual fund dealers and persons acting on their behalf. This is further to the delegation of registration functions already made by Alberta, New Brunswick, Newfoundland and Labrador, Nova Scotia, Ontario, Prince Edward Island, Quebec, and Yukon. Manitoba and British Columbia are expected to follow, but their timing is not known.

Key Contacts

BLG Beyond AUM Law - Bill Donnegan

 

Regulatory Compliance Counsel and Consultants to Securities Registrants – BLG Beyond AUM Law was founded in 2009 with a vision to serve the regulatory compliance needs of securities registrants. BLG Beyond AUM Law has been part of Borden Ladner Gervais LLP (BLG) since May 2021 and is integrated with BLG’s suite of alternative legal services known as BLG Beyond. BLG Beyond AUM Law offers practical, cost-effective legal and consulting advice on securities regulatory compliance matters.

 

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