Overview
The Canadian Investment Regulatory Organization (CIRO) will have enhanced registration functions on April 1, 2025.
Nine Canadian Securities Administrators (CSA) jurisdictions are expected to delegate to CIRO registration functions for investment dealers (ID), mutual fund dealers (MFD), and the individuals who act on behalf of these firms, subject to local approvals. Other CSA jurisdictions are considering similar delegation.
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 delegated authority for ID individuals only and Manitoba, Nova Scotia, Prince Edward Island, Northwest Territories, Nunavut and Yukon had not yet delegated. As such, delegation was not yet consistent across the nation (see Table 1 under “Changes to delegation effective April 1”).
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.
CSA announcements and FAQs are available at: Streamlining registration delegation to Canadian Investment Regulatory Organization.
Changes to delegation effective April 1, 2025
Delegation of registration functions to CIRO as at April 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 April 1 subject to local approvals
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 are continuing to review applications for registration and other submissions filed before April 1, 2025
- For an interim period following April 1, 2025, 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.
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].