CIRO’s 2025 Industry Business Continuity Planning Test Completed

Overview

On Saturday, October 25, 2025, CIRO’s biennial industry business continuity planning (BCP) trading simulation test was successfully completed.

In addition to the trading simulation, an Incident Response Plan (IRP) exercise and crisis communication test were successfully conducted on Tuesday, December 2, 2025.

Overall, the 2025 industry BCP test demonstrated the ability of the Canadian investment industry to put into practice their BCP protocols in response to a significant disruption to business operations.

Background and purpose

On March 24, 2025, CIRO notified the Canadian investment industry of the industry BCP test in Administrative Bulletin 25-0087 CIRO’s Industry Business Continuity Planning Test – October 25, 2025 – Save the Date.

The industry BCP test is conducted in accordance with section 12.4.1 of National Instrument 21-101: Marketplace Operation (NI 21-101). Additionally, the industry BCP test aligns with Investment Dealer and Partially Consolidated Rule 4700, Part A, as well as Mutual Fund Dealer Rule 2.9 and MSN-0056.

Scope

PricewaterhouseCoopers LLP (PwC) was engaged to facilitate the 2025 industry BCP test.

The 2025 industry BCP test was comprised of three components:

1. Trading simulation
2. Incident Response Plan exercise
3. Crisis communication test.

The trading simulation covered a variety of investment products, with Dealer Members testing from their production and primary data processing sites, marketplaces and recognized clearing agencies, as well as information processors testing from their disaster recovery data processing sites.

The IRP exercise was based on a simulated market disruption incident, developed by PwC in collaboration with Canadian Securities Administrators (CSA) representatives and CIRO. Exercise participants were provided with a hypothetical scenario, which was divided into four segments, and were expected to respond to a brief survey of questions following each segment.

The crisis communication test involved two-way communication between CIRO and designated contacts at Dealer Members and Canadian equity marketplaces.

Participants

Participant Dealers with annual trading volumes at or above 1 billion net shares (based on 2024 trading data), marketplaces, recognized clearing agencies, and information processors, were required to participate in the trading simulation. All other Dealer Members and service providers were encouraged to join voluntarily. All required stakeholders fulfilled their participation requirements. A total of 71 Dealer Members participated in the trading simulation.

All Participant Dealers, marketplaces, and clearing agencies were required to participate in the IRP exercise, and participation was completed by all stakeholders.

All Dealer Members and marketplaces were required to participate in the crisis communication test, which achieved an overall response rate of 97%. Follow-up was conducted with the limited number of Dealer Members that did not participate.

We would like to express our sincere gratitude to our Dealer Members, as well as marketplaces, service providers, and other market participants, for their cooperation and involvement in this important initiative.

Next steps

CIRO will issue a report to exercise participants outlining recommendations to strengthen their BCP testing capabilities, incident response and communications protocols to support future planning and operational readiness.

CIRO will also use the input and recommendations received from stakeholders as part of the 2025 industry BCP test to inform the next biennial BCP test.

If you have any questions about the test, please contact [email protected].