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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

  • July 23, 2026 - CIRO published the next iteration of its proposed rule amendments to modernize the requirements for account transfers and bulk account movements applicable to investment dealers and mutual fund dealers. The proposals are intended to minimize client service disruptions when a client transfers their account from one firm to another. Material revisions to the initial proposal include: (i) a clarification that accounts that are subject to a temporary hold may not be transferred until the hold is removed by the delivering dealer; (ii) the delivering and receiving dealers should both make best efforts to complete each account transfer step as soon as practically possible; and (iii) unbundling of the proposed timelines for various actions preceding a transfer. A full list of the material revisions to the initial proposal and the proposed rule amendments to the rules are set out in Bulletin 26-0161. Comments on the proposed amendments are due by October 21, 2026.
  • July 9, 2026 – CIRO published its proposed harmonized approach to Approved Person compensation which: (1) retains the current options for any client-facing Approved Person to be an employee or an agent of the sponsoring dealer; (2) repeals the directed commission arrangement option currently available; and (3) introduces the option for any client-facing Approved Person to enter into an incorporated advisor arrangement under a written agreement with the dealer, the corporation and the individual. There are numerous conditions to the proposed incorporated advisor arrangement, including that the corporation must be approved by CIRO as an “Incorporated Approved Person”, the individual agent associated with the corporation must be a client-facing individual Approved Person of the dealer, and voting shares must be held by the individual agent while non-voting shares can only be held by the individual agent and “related persons” under the Income Tax Act (Canada). The activities to be performed within the corporation (in addition to activities performed on behalf of the relevant dealer) would be limited to those CIRO determines to be ancillary activities, or in certain cases, regulated Canadian financial service sector activities. Comments on the proposed rules are required to be delivered to CIRO and applicable CSA members by November 6, 2026.
  • June 24, 2026 – CIRO published new Guidance on the Fit and Proper Test for Approved Persons (GN-9200-26-001), reiterating that CIRO staff will evaluate applications for registration to determine whether an individual is suitable or “fit and proper" based on three fundamental criteria: integrity, financial solvency, and competence. CIRO staff will also consider whether registration is in the public interest or is otherwise objectionable. The full list of factors that Staff evaluates is set out in the Guidance. A more extensive review may occur if an approval or registration application contains certain disclosure on Form 33-109F4 Registration of Individuals and Review of Permitted Individuals (e.g. with respect to resignations and terminations) and the Guidance includes a list of the supporting documents Staff expects will accompany any such application. The Guidance includes a discussion on best practices for Dealers in conducting due diligence on prospective Approved Persons, while cautioning that failure to take reasonable steps to conduct due diligence may put into question the Dealer's own ongoing fitness for registration.

Key Contacts