Becoming a Dealer Member

General Information

Under securities regulations, to carry on business in Canada, investment dealers and mutual fund dealers are required to become CIRO Dealer Members. A firm is eligible for membership in CIRO if:

it is formed under Canadian federal, provincial or territorial law. A firm outside Canada would need to create a Canadian entity that would apply for CIRO membership;
it proposes to carry on business in Canada as a dealer;
it is registered or licensed in each jurisdiction in Canada where the nature of the business requires registration or licensing;
it is in compliance with applicable securities legislation and the requirements of any securities regulatory authority having jurisdiction over it; and
the firm and its directors, partners, officers, employees and agents, will comply with the By-laws, Rules, and Policies of CIRO.

Firms should only submit their membership application if they intend to commence their dealer business upon obtaining CIRO approval, or shortly after.

Membership Application Process

Becoming a CIRO dealer is a collaborative process that requires applicants to present a well-defined business model with key elements finalized. The completeness and quality of the application, along with timely and accurate responses, are essential for progressing the review efficiently and ensuring CIRO can uphold its response timelines.

The process for applying for CIRO membership is outlined below. Additionally, where CSA members have delegated the registration of investment dealers, mutual fund dealers, or futures commission merchants to CIRO, CIRO will review the firm’s application for firm registration (Form 33-109F6).

If you have questions or need further assistance, please contact [email protected].

Prepare the Application

1. Complete the Membership Application Readiness Questionnaire (PDF) to self-assess the firm’s preparedness for applying for CIRO membership.

The Readiness Questionnaire will assist the firm in determining whether it has the required infrastructure, capital, policies & procedures, systems, and key personnel to begin the process of applying for membership.

2. Review the Guidance for Applicants (PDF) and the New Membership Application – Documentation Checklist (PDF) for information on the materials that applicants must prepare. For applicants who are Crypto Asset Trading Platforms, please also refer to the Supplemental Documentation Checklist for Crypto Asset Trading Platforms (PDF).

The Guidance for Applicants (PDF) describes what CIRO staff will review for a membership application. The Documentation Checklist (PDF) sets out the additional materials, forms and supporting documents that must be included with the application. For Crypto Asset Trading Platforms (CTPs) applying for CIRO membership, please refer to the Supplemental Documentation Checklist for Crypto Asset Trading Platforms (PDF) alongside the Documentation Checklist (PDF). This supplemental checklist details the additional documents required as part of the CTP’s New Membership Application.

Applications for membership undergo an extensive review by CIRO staff. This includes review and analysis of the materials submitted, and discussions with the applicant’s management and technical personnel. Reviewing the above guidance ahead of time will help the firm assess whether it is ready to begin the membership application process.

We encourage applicants to seek guidance from a compliance consultant or legal counsel specialized in Canadian securities legislation and CIRO rules, to ensure they are well prepared to apply for CIRO membership.

3. Contact CIRO’s Membership Intake team at [email protected] to book an introductory meeting.

During the introductory meeting, CIRO staff will guide the firm through the application process, discuss relevant timelines, and identify key areas of the firm’s business that will be assessed during the review. The meeting is also a helpful venue for CIRO staff to meet the applicant’s principals and obtain information regarding the applicant’s overall business plan.

Submit the Application & Fee

4. Submit a fully completed Membership Application (PDF) and the required supporting materials to CIRO.

Once the applicant is ready to apply for membership, contact [email protected] to receive a ShareFile link and instructions for uploading the membership application package. Incomplete applications or applications with material deficiencies will not be accepted for review.

Applicants can avoid unnecessary delays in the review and processing of their membership application by:

ensuring all sections of the Membership Application (PDF) are completed in full; and
including all supporting documents with their Membership Application (refer to the Documentation Checklist (PDF)).

Once CIRO staff have determined the submission to be substantially complete, CIRO will provide a written confirmation to the firm that their application has been accepted for review.

5. Apply for registration as a Dealer with the securities regulatory authority in the applicable jurisdictions.

In Canada, becoming registered as an investment dealer, a mutual fund dealer, or a dual-registered firm, is a two-pronged process. The firm must:

apply to become a member of CIRO; and
apply for registration with the applicable securities regulatory authority of the Canadian Securities Administrators (CSA) in each jurisdiction the firm intends to operate.

If the applicant’s head office is in a jurisdiction where the CSA member has delegated the firm registration function to CIRO, the applicant must include their completed Form 33-109F6 (PDF) when submitting their membership application to CIRO. CIRO will review the Form 33-109F6 in parallel with the firm’s membership application. Refer to Delegation of additional registration functions to CIRO for more information regarding delegation of firm registration.

Information on how to apply for dealer registration with CSA members that have not delegated firm registration to CIRO can be found on the CSA members’ websites. Links to the websites for each CSA member are provided in the Regulatory Links below.

6. Pay Entrance Fee.

Once CIRO accepts a membership application for review, the applicant must pay a non-refundable Entrance Fee. CIRO staff will provide the wire transfer instructions for submitting the payment.

The amount of the non-refundable Entrance Fee is specific to the type of Dealer:

$10,000 non-refundable Entrance Fee for a Level 1, 2 or 3 Mutual Fund Dealer
$10,000 non-refundable Entrance Fee for a Level 4 Mutual Fund Dealer
$30,000 non-refundable Entrance Fee for an Investment Dealer or Dual-Registered Dealer
$40,000 non-refundable Entrance Fee for an Investment Dealer – Crypto Asset Trading Platform.

Refer to CIRO Rules Bulletin 25-0017 – Integrated Fee Model for further information on the fee model.

While Your Application is Under Review

7. File Monthly Financial Reports (MFRs) starting the month the membership application is accepted for review.

Please contact Heather Barclay at [email protected] or Nellie Gomes at [email protected] to be set up on SIRFF.

8. Respond to follow-up information requests from CIRO staff during the review process.

All membership applications undergo an extensive review with respect to financial & operations compliance, business conduct compliance, trading conduct compliance and registration requirements. Applicants will not be admitted to membership until they can demonstrate that they can meet these requirements.

Generally, the time for review of a membership application is approximately six months. However, applications for firms with complex or novel business models can take much longer. The completeness of the applicant’s initial and subsequent submissions to CIRO and the timeliness of their responses to information requests, will also significantly impact the time it will take to process the application.

In accordance with CIRO’s Internal Fee Model Guidelines and CIRO By-law No. 1, paragraph 3.5(4), if CIRO’s review or consideration of an application requires excessive attention, time and resources, CIRO’s Board of Directors may require the applicant to reimburse CIRO for its costs and expenses attributable to the review of the application.

Note that during the review process, you will also be requested to submit filings related to individual registrants through the National Registration Database (NRD) in accordance with NI 33-109.

Application Approval

9. Wait for CIRO confirmation of membership approval.

Once CIRO staff have completed our compliance review of the membership application and are satisfied that the application meets membership requirements, the application will be submitted to CIRO’s Board of Directors for consideration. The Board will decide whether to:

approve the membership application;
approve the membership application with terms and conditions; or
reject the application.

CIRO will notify the applicant in writing of the Board’s decision. Once the Board approves the application, the firm will be admitted to membership once administrative requirements have been finalized (e.g., payment of any remaining fees), and the applicable CSA jurisdictions have confirmed approval of the firm's registration.

10. Ongoing membership requirements.

Once accepted into membership, the Dealer Member can commence business and will be subject to various ongoing requirements, including regulatory and financial reporting. Many of these reporting requirements have filing deadlines and, in some cases, the firm may be charged late filing fees.

Dealer Members must also inform CIRO of any material changes to information originally submitted to CIRO in the firm’s membership application or registration application (where firm registration has been delegated to CIRO). Examples of material changes with respect to the Dealer Member include:

change in business activities, such as adding new products or services;
change of name or address for service;
change in registration or licensing with the relevant securities commission;
changes in ownership and control;
reorganizations, mergers, and amalgamations;
civil proceedings; and
change in, or refusal of, insurance bond.

Many of these changes require prior notification to CIRO or prior approval from CIRO. Members should refer to CIRO By-laws, the Investment Dealer and Partially Consolidated Rules or the Mutual Fund Dealer Rules, as applicable, and National Instrument 33-109 to determine the reporting requirements applicable to their firm.

Service Standards

CIRO is committed to adhering to service standards associated with the processing of new Member applications and the firm’s registration application (where CIRO has been delegated firm registration).

Our service standards, summarized in the table below, outline CIRO’s response timelines for each submission made by the applicant, whether it is the initial New Member Application submission or a response to an information request from CIRO staff during the review process. These service standards ensure transparency and consistency, providing applicants with clear expectations from CIRO during the course of our review of the Member Application.

Applicant Submission	CIRO Response	Service Standard
New Member Application Applicant submits a completed New Member Application along with supporting documentation and uploads the material to the ShareFile link provided by CIRO’s Member Intake team.	Completeness Check CIRO will verify whether the Application is sufficiently complete to accept for review. If the Application is sufficiently complete, CIRO staff will send the applicant a confirmation of acceptance and wire instructions for the non-refundable Entrance Fee. If the Application is not sufficiently complete to accept for review, CIRO staff will notify the applicant of this determination, along with the material deficiencies in their Application.	10 business days from receipt of the Application
Payment of Entrance Fee Applicant’s payment of the non-refundable Entrance Fee is received by CIRO	Initial Comments on the Application CIRO staff will provide the applicant with a consolidated list of initial questions and comments regarding the Application.	10 business days from receipt of the non-refundable Entrance Fee
Subsequent Applicant Submissions During CIRO’s review of the Application, the applicant will provide subsequent materials and information to CIRO staff to support its Application.	Response to Subsequent Applicant Submissions CIRO staff will respond to follow-up written submissions from the Applicant throughout the review process.	20 business days from receipt of written responses and subsequent materials from the applicant

Applicant Submission

CIRO Response

Service Standard

New Member Application

Applicant submits a completed New Member Application along with supporting documentation and uploads the material to the ShareFile link provided by CIRO’s Member Intake team.

Completeness Check

CIRO will verify whether the Application is sufficiently complete to accept for review.

If the Application is sufficiently complete, CIRO staff will send the applicant a confirmation of acceptance and wire instructions for the non-refundable Entrance Fee.

If the Application is not sufficiently complete to accept for review, CIRO staff will notify the applicant of this determination, along with the material deficiencies in their Application.

10 business days from receipt of the Application

Payment of Entrance Fee

Applicant’s payment of the non-refundable Entrance Fee is received by CIRO

Initial Comments on the Application

CIRO staff will provide the applicant with a consolidated list of initial questions and comments regarding the Application.

10 business days from receipt of the non-refundable Entrance Fee

Subsequent Applicant Submissions

During CIRO’s review of the Application, the applicant will provide subsequent materials and information to CIRO staff to support its Application.

Response to Subsequent Applicant Submissions

CIRO staff will respond to follow-up written submissions from the Applicant throughout the review process.

20 business days from receipt of written responses and subsequent materials from the applicant

Where there are extenuating or unforeseen circumstances that may prevent us from meeting these service standards, CIRO staff will work with the applicant to establish an appropriate timeline for next steps.

Expectations from the Applicant:

The completeness of the applicant’s initial and subsequent submissions to CIRO and the timeliness of the applicant’s responses to information requests, will significantly impact the time it will take to process the Application. To keep the review process moving forward, CIRO staff will establish deadlines for the applicant to provide responses or additional material. Applicants are expected to provide substantially complete and accurate responses within the specified timeline to ensure steady progress in the review. If an applicant anticipates being unable to meet a deadline, they may request an extension in writing.

If any of the applicant's responses or submissions during the review process introduce material changes to the original business proposal, this may impact CIRO's response times as additional considerations become necessary, potentially delaying the overall review timeline. Firms are encouraged to carefully review their business plans to ensure material elements have been finalized prior to filing and application for CIRO membership.

Additional Resources

Guidance for Applicants (PDF)
Integrated Fee Model (PDF) – effective April 1, 2025
Choosing a Carrying Broker (PDF)
Panel Auditor (PDF)