Delegation of additional registration functions to CIRO

Overview

The Canadian Investment Regulatory Organization (CIRO) gained enhanced registration functions on April 1, 2025 and as at July 1, 2025.

Twelve Canadian Securities Administrators (CSA) jurisdictions have delegated registration functions to CIRO for investment dealers (ID) and the individuals who act on their behalf, and ten have delegated firm and individual registration functions for mutual fund dealers (MFD). Other CSA jurisdictions are considering similar delegation.

Most recently, the Autorité des marchés financiers (AMF) announced their delegation of ID, MFD and Derivatives Dealers, as well as the individuals who act on behalf of MFD, effective July 1, 2025.

This initiative supports a consistent and harmonized approach to registration and creates efficiencies in line with the evolving needs of investors and dealers across Canada. The benefits of streamlining registration functions with CIRO were discussed in CIRO’s Strategic Plan for Fiscal Year 2025-2027.

Background

CIRO had previously been delegated authority to register firms and individuals who act on behalf of IDs in Alberta, British Columbia, New Brunswick, Newfoundland and Labrador, and Saskatchewan. Ontario and Québec had delegated authority for ID individuals only and Manitoba had not yet delegated.

A key objective outlined in CIRO’s Strategic Plan for 2025-2027 was to engage with CSA jurisdictions to explore delegating the registration of all ID and MFD individuals to CIRO. This goal aligns with the CSA’s recommendations in Position Paper 25-404 New Self-Regulatory Organization Framework which proposed assessing the allocation of registration functions between CSA jurisdictions and the new SRO following its creation.

The Government of Québec approved the Autorité des marchés financiers' decision on September 20, 2023 to delegate the powers of registration of mutual fund representatives to CIRO, as well as the powers of examination of mutual fund dealers with activities in Québec.

On November 20, 2024, the Ontario Securities Commission (OSC) announced its intention to delegate, subject to all required regulatory approvals, the registration of investment dealers, mutual fund dealers, and individuals acting on behalf of mutual fund dealers to CIRO, effective Spring 2025. On the same day, the CSA also announced its intention to explore further streamlining registration delegation to CIRO, consistent with the objectives outlined in its 2022-2025 Business Plan. The CSA announcements and FAQs are available at: Streamlining registration delegation to Canadian Investment Regulatory Organization.

On April 1, 2025, nine CSA jurisdictions delegated to CIRO registration functions for ID and MFD firms and individuals.

The AMF delegated registration functions for ID, MFD and Derivatives Dealers and individuals who act on behalf of MFD on July 1, 2025.

With the additional delegation of powers on April 1, 2025 and as at July 1, 2025, delegation of registration functions across the country for ID and MFD is largely harmonized.

Changes to delegation as at July 1, 2025

Delegation of registration functions to CIRO as at July 1, 2025 is expected to be as follows, subject to local approvals. The remaining CSA jurisdictions are continuing to explore delegation to CIRO.

Province / Territory	Investment Dealers		Mutual Fund Dealers
	Individuals	Firms	Individuals	Firms
Alberta
British Columbia
Manitoba
New Brunswick
Newfoundland and Labrador
Northwest Territories
Nova Scotia
Nunavut
Ontario
Prince Edward Island
Québec
Saskatchewan
Yukon

- Current state

- Additional delegation effective July 1, 2025.

Implications for CIRO Members

Enhancing CIRO’s registration functions modernizes and streamlines the registration process, improving efficiency for firms and individual applicants. The key objectives are to:

• Establish a consistent and harmonized approach to registration
• Enhance efficiencies to meet the evolving needs of investors and dealers across Canada and
• Reduce the regulatory burden for registrants through CIRO’s national registration program while minimizing overlap with the CSA

CSA and CIRO staff are working together to help ensure a smooth transition of registration responsibilities.

• CSA staff in jurisdictions that delegated on April 1, 2025 are continuing to review applications for registration and other submissions filed before April 1, 2025. The AMF will continue to review submissions filed before July 1, 2025
• Submissions filed in delegated jurisdictions after those times will be reviewed by CIRO staff.
• For an interim period, background checks on individuals will be conducted by CSA jurisdictions. For this reason, members may still be contacted by the CSA regarding submissions.

Registration Filings

There is no change to the information, materials, or fees that firms and individuals are required to submit with respect to applications for registration and updates to registration information, with the exception of fees for individuals acting on behalf of mutual fund dealers in Québec.

Firms applying for registration as an ID or MFD must still complete and file Form 33-109F6 Firm Registration, and firms reporting changes in registration information must still complete and file Form 33-109F5 Change of Registration Information. Where delegation has taken place, firms will submit these registration filings and applicable fees to CIRO. For efficiency, existing CIRO processes for membership-related applications, notices and updates will be leveraged to handle registration filings.

CIRO has detailed guidance on our website to assist firms:

• For firms applying for CIRO membership, refer to Becoming a Dealer Member on our website
• For existing CIRO Members:
  • For information on notifying CIRO of a material business change, refer to Notice of Business Changes
  • For information on notifying CIRO of ownership changes, refer to Notice of Ownership Changes
  • All other changes to firms, including updates to firm information and notices of voluntary surrenders or resignation, should be submitted to [email protected]

The filing process for individual registration categories remains the same using the National Registration Database (NRD).

Individuals applying for registration or a review as a permitted individual, must still complete and file Form 33-109F4 Registration of Individuals and Review of Permitted Individuals or other applicable forms under National Instrument 33-109 Registration Information and pay the appropriate fee through NRD. The filings will be automatically routed to CIRO’s Registration department for processing where delegation has taken place in the applicable filing jurisdiction(s).

CIRO has also been delegated the authority to approve or object to notices provided under section 11.9 and 11.10 of National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations for acquisitions where there has been delegation for the firms and individuals involved.

Additional resources and contact information

For more details, please refer to our Frequently Asked Questions.

If you have additional questions related to the Delegation of Registration, please contact us at [email protected].