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

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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

  • September 10, 2026 – CIRO published its bulletin “Client Focused Reforms (CFR) – Targeted Compliance Guidance: Practical steps to help Dealer Members (“Dealers”) and Approved Persons (“APs”) meet their regulatory obligations and protect investors” (the Guidance). Based on deficiencies and observations during regulatory reviews and examinations, the Guidance supplements Joint Staff Notice 31-368 Client Focused Reforms: Review of Registrants’ Know Your Client, Know Your Product and Suitability Determination Practices and Additional Guidance by providing practical examples to support compliance with the KYC obligation. Specifically, the Guidance provides practical steps and examples of acceptable practices for collecting sufficient financial information, assessing liquidity needs, risk capacity and determining an overall risk profile for a client. CIRO has noted that this is the first bulletin in a series of compliance bulletins that will be published to assist Dealers and APs with their CFR obligations.
  • 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.

Key Contacts