Access to Online Advice in the Advisory and Managed Channels

Response Due By: Jan 31, 2026

Introduction

The Canadian Investment Regulatory Organization (CIRO) is evaluating access to online advice for advisory and managed accounts.

Consistent with CIRO’s strategic objective to enable greater access to advice as outlined in the CIRO Strategic Plan FY 2025-2027 published on April 11, 20241, on December 13, 20242, CIRO published a consultation paper on non‑tailored advice in the Order Execution Only (OEO) channel. This was followed on August 12, 20253, by proposed guidance enabling OEO Dealers to offer more educational resources to do-it-yourself (DIY) investors so they can access trustworthy information to make informed investment decisions. OEO Dealers play a crucial role in Canada’s retail investment market by offering investors low‑cost access to capital markets and greater control over their own investment choices.

At the same time, a fully self-directed approach does not work for every investor. Some investors may benefit from more affordable, scalable access to tailored advice. Closing this gap includes supporting innovation that complements the OEO model, recognizing that both OEO and advisory channels are distinct and essential components of a well‑functioning retail investment market.

Therefore, to further advance the objective of enabling greater access to advice, we are evaluating whether CIRO should consider developing policy to help expand online advice options across CIRO Dealer Members, including hybrid and automated models. While these alternatives may look different than the traditional advisory model, they have the potential to broaden access to regulated advice to a wider range of investors.

Context and Issues

The recent CIRO initiative to modernize the OEO framework responds to the evolving needs of DIY investors. The revisions improve access to information and decision‑making supports through regulated channels, ensuring investors get reliable, timely, and high‑quality inputs to make independent, well‑informed decisions.

Building on this progress, a targeted review of how the current regulatory framework applies to tailored online advice will be an important next step to determine whether adjustments are needed to support affordable, scalable tailored advice delivered through online and hybrid advisory and managed models.

The objective is to identify key regulatory barriers in CIRO’s current policy framework, which was built for in-person advisory services and may inhibit innovation in tailored online advice. There is currently no specific regulatory framework for Dealer Members using online or hybrid advisory models. Instead, they rely on exemptive relief and special terms and conditions.

As a result:

• online advice models, including hybrid services, are costly to operate and have limited product shelf,
• Dealer Members face uncertainty regarding regulatory requirements when advice is delivered online,
• compliance expectations may be interpreted inconsistently across the industry, and
• the lack of a specific framework may stymie the development of online advice solutions.

Consequently, a significant portion of Canadians (particularly small‑balance, early‑stage, and digital‑first investors) would be better served by access to more affordable tailored advice, given Dealer Members’ technological capacity to deliver it and many Canadian investors being comfortable in an online environment.4

Potential Solutions

Based on the above problem statement, and informed by thorough stakeholder engagement, we will consider whether further policy development (such as rule and guidance clarifications, or other recommendations) is required.

Next Steps

The initiative will seek to expand access to online advice by:

• assessing our rules and guidance in the digital context,
• identifying areas where regulatory requirements could be met through technology-augmented means, and
• examining any unintended consequences arising from current frameworks.

We are seeking engagement from stakeholders, including Investment Dealer Members, Mutual Fund Dealer Members, industry representatives, investor advocates and the public, on the issues identified above and potential solutions. We anticipate the discussions to also include online advice platforms’ ability to expand into a wider range of offerings (e.g., private equity, direct indexing, model portfolios), and the related application of Client Focused Reforms. In addition, evolving considerations such as addressing challenges posed by finfluencers through greater access to tailored online advice, strengthening cyber‑risk controls in online advice models, and leveraging advanced digital and automation technologies (such as artificial intelligence) to enhance compliance processes and innovation may form part of the dialogue.

Any material future proposals will be developed in collaboration with the Canadian Securities Administrators and will be subject to approval under CIRO governance procedures.

How to Participate

This initiative represents an important opportunity to collaboratively shape access to online advice.

Should you wish to participate or require further information, please contact the Member Regulation Policy team in writing by Jan 31, 2026, at:

Member Regulation Policy
Canadian Investment Regulatory Organization
Suite 2600
40 Temperance Street
Toronto, Ontario M5H 0B4
e-mail: memberpolicymailbox@ciro.ca

• 1CIRO Strategic Plan FY 2025-2027
• 2Administrative Bulletin 24-0367 Non tailored advice in the order execution only channel
• 3Administrative Bulletin 25-0227 Guidance on order execution only account services and activities
• 4CIRO’s 2024 Investor survey shows that many Canadian investors are comfortable online, including transacting digitally and a clear preference for receiving account information via online platforms or apps.