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.
We have compiled a set of Frequently Asked Questions (FAQs) to address key questions. If you have additional questions related to the Delegation of Registration, please contact us at [email protected].
This page will be updated as additional information becomes available.
General Information
1. What registration functions are being delegated to CIRO?
Delegation of registration functions to CIRO as at April 1, 2025 is expected to be as follows, subject to local approvals:
| 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
CIRO will be handling the registration functions for the following registration categories under delegation:
Firm categories
- Investment dealer (ID)
- Mutual fund dealer (MFD)
- Futures commission merchant (FCM) in Ontario
Individual categories (at the above noted firms)
- Ultimate designated person (UDP)
- Chief compliance officer (CCO)
- Dealing representative (DR)
- Salesperson, Partner and Officer of FCMs
CIRO will also handle the review of permitted individuals (PIs) with IDs and MFDs.
2. What was CIRO’s involvement in the registration of these categories previously?
CIRO had previously been delegated authority in some CSA jurisdictions to conduct registration functions for both ID firms and individuals who act on their behalf. Certain other jurisdictions delegated for ID individuals only and others had not yet delegated. Expanding this delegation establishes a more consistent and harmonized process for CIRO Members nationwide.
3. CIRO will now have delegated authority for MFD registration for firms and individuals. What does this mean for CIRO Members who are MFDs?
MFD Members will now have their firm and individual registration handled by CIRO from April 1, 2025 onwards where the registration function has been delegated. CIRO staff will be your point of contact should you have any questions about your filing.
4. What if there is a registration category involved that is not subject to delegation?
Firms or individuals requiring registration in categories that are not being delegated to CIRO (e.g., exempt market dealer, investment fund manager) will have a coordinated review and approval by both CIRO and the appropriate CSA jurisdiction.
5. Who handles registration submissions already in progress?
Applications and submissions filed with the CSA before April 1, 2025 will be completed by the appropriate CSA jurisdiction. Filings on April 1, 2025 going forward will be handled by CIRO where delegation has occurred. CSA jurisdictions and CIRO are working together to ensure a smooth transition.
6. Are there changes to my filing fees?
No. There are no changes to filing fees due to delegation at this time.
7. Have the filing forms changed?
No. There has been no change in the registration forms and information required to be submitted under delegation. Firms and individuals must still use the forms required under National Instrument 33-109 Registration Information.
8. What is not being delegated to CIRO?
Portfolio managers, restricted portfolio managers, investment fund managers, exempt market dealers, restricted dealers, and scholarship plan dealers, as well as individuals who act on behalf of these firms, will continue to register with, and be overseen by, the appropriate CSA jurisdiction.
MFDs that are not CIRO Members, as a result of legacy exemptive relief from the requirement to be registered with the former Mutual Fund Dealers Association of Canada, will be handled by the appropriate CSA jurisdiction.
Specific to Ontario, commodity trading advisers, commodity trading counsels and commodity trading managers will also continue to register with and be overseen by the Ontario Securities Commission (OSC).
Should significant or novel issues arise in the course of registration submissions being handled by CIRO, the appropriate CSA jurisdiction will still be involved. CSA jurisdictions have concurrent authority and exercise oversight.
Filings for individuals
9. Is the process changing for individual registration filings?
No, the filing process for the individual registration categories remains the same using the National Registration Database (NRD). There is no new information or changes to the information individuals need to provide as a result of delegation. Individual filings will be automatically routed to CIRO’s Registration department for processing where delegation has taken place in the applicable filing jurisdiction(s).
For more information on applying for registration, please see the CSA NRD Information Site.
10. Is the process changing for applications by individuals for proficiency exemptions?
No. The process remains the same for MFD individuals submitting applications for exemptions to proficiency requirements in National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations. Exemptive relief filings should continue to be made on NRD for processing by CIRO where delegation has taken place in the applicable filing jurisdiction(s).
Filings for firms
11. Is the process for CIRO Members filing updates to firm registration changing?
Not significantly. There are no changes to the information, materials or fees that firms are required to submit. Where delegation has taken place, firms will submit these registration filings and applicable fees to CIRO.
There are two minor process changes:
- Form 33-109F5 Change of Registration Information, which was previously submitted to the applicable CSA jurisdiction, must now be submitted to CIRO, and
- We have created a new mailbox [email protected] for Members to file certain firm registration updates, as outlined below.
12. What is the process for firms applying to become an ID or MFD?
Firms applying for registration as an ID or MFD must still complete and file Form 33-109F6 Firm Registration. Where delegation has taken place, firms will submit the required registration filings and fees to CIRO, along with their application for CIRO membership. Please refer to Becoming a Dealer Member on our website for further information.
13. What is the process for CIRO Dealer Members making changes to their registration?
When reporting changes in their registration, CIRO Dealer Members must still complete and file Form 33-109F5 Change of Registration Information. In jurisdictions where the registration function has been delegated to CIRO, Members will submit the required registration filings and fees to CIRO. For efficiency, existing CIRO processes for membership-related notices and updates will be leveraged to handle registration filings:
- For information on notifying CIRO of a material change in business, refer to Notice of Business Changes
- For information on notifying CIRO of a change in ownership of the Member or its holding companies, refer to Notice of Ownership Changes
- All other changes, including updates to firm information and notices of voluntary surrenders or resignation, should be submitted to [email protected].
14. Are notices under sections 11.9 and 11.10 of National Instrument 31-103 included in the delegation of registration functions to CIRO?
Yes, 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. Refer to Notice of Ownership Changes for detailed guidance on how to provide the required notice to CIRO.