Amendments to harmonize CIRO Continuing Education Programs – Phase 1

1. Background

1.1 History

On April 11, 2024 CIRO published its Strategic Plan FY 2025 -2027, which included a public commitment to harmonize the Investment Dealer (ID) and Mutual Fund Dealer (MFD) CE programs2. Harmonization of the CIRO CE programs (CE Harmonization) was subsequently included in the CIRO 2025 Annual Priorities.3 Our commitment to develop a plan for CE harmonization was adapted from the 2021 CSA recommendations to streamline CE for all ID and MFD dealer members4 in order to strengthen the regulatory regime’s proficiency framework.

On December 19, 2024, we published the Amendments, as proposed in Bulletin 24-0356, which reflected:

• material differences between the IDPC and MFD Rules for CE,
• the objectives of the current MFD and IDPC CE programs, which is to further develop baseline proficiencies applicable to Approved Persons consistent with the proficiency principle,
• the objectives of CE harmonization and applicable regulatory requirements, including those specific to Quebec, and
• the potential operational and IT system impacts of harmonized rules on all CIRO firm types.

The objectives of the Amendments were to:

• allow for a phased approach to minimize IT systems and operational impact,
• emphasize firm responsibilities for proficiency and supervision of CE including responsibility for record-keeping and reporting,
• promote a principles-based approach for firms to approve CE course/activity and a harmonized accreditation approach, and
• ensure consistency with the CIRO Proficiency Model for Approved Persons under the Investment Dealer and Partially Consolidated Rules5, including eliminating carry forwards and the Voluntary Participation Program.

1.2. Phased approach

The Amendments form the first part of a two phased approach to CE harmonization to ensure:

• timely harmonization of material differences between CIRO CE programs, where possible, and
• adequate collection and analysis of feedback and information on rules that have a more significant impact on current complex operational and IT systems.

Phase 1 of CE Harmonization was initially intended to be implemented at the start of a new CE cycle starting on January 1, 2026, with Phase 2 rule amendments to follow in the subsequent CE cycle. However, after considering comments provided on Phase 1, we decided to delay the Phase 1 implementation in order to coincide with a future Phase 2 implementation date because of the number of commenters advocating for a single implementation date for both Phases 1 and 2 together, or those who expressed concerns about timing for Phase 1 alone.

We believe that a single implementation date for Phases 1 and 2 is reasonable in order to move forward with completing our plan for CE harmonization for all dealer types and Approved Persons. It will also give dealers the additional time needed to assess related operational and IT system impacts.

By delaying Phase 1, we hope to provide more sufficient time for the project to be implemented alongside, or at a similar time to, the harmonized CIRO Rules, in accordance with the Rules Consolidation Project6, which is a separate CIRO project with its own specific timing.

We intend to publish Phase 2 of the CE harmonization proposals for comment in the spring of 2026. Phase 2 will include amendments that will have more significant operational and/or IT system impacts and require further consideration and a longer implementation timeline.

2. Comments received

We received 17 public comment letters in response to Bulletin 24-0356. We provide a summary of these comments and our response in Appendix 6.

3. The Amendments

The Amendments are contained in IDPC Rules 2700 and MFD Rules 1.2 and 900, where we:

• clarify firm record-keeping and reporting responsibilities for CE in the MFD Rules,
• eliminate the restriction on CE course repeats in the IDPC Rules,
• eliminate mandatory accreditation requirements in the MFD Rules,
• expand the scope of what types of CE courses or activities qualify for CE credit under the MFD Rules,
• eliminate carry forwards in the MFD Rules for alignment with the removal of carry forwards in the IDPC Rules under the CIRO Proficiency Model for Approved Persons under the Investment Dealer and Partially Consolidated Rules7, and
• eliminate the Voluntary Participating Program from the IDPC Rules CE Rules for alignment with the CIRO Proficiency Model for Approved Persons under the Investment Dealer and Partially Consolidated Rules8.

Clean and Blackline copies of the Amendments are respectively set out in Appendices 1 to 5.

4. Early implementation of Amendment to eliminate Voluntary Participation Program in the IDPC Rules - January 1, 2026

Current IDPC Rule 2726 establishes a Voluntary Participation Program (VPP), which extends the validity period of the baseline proficiency Canadian Securities Course (CSC) for one CE cycle. On January 1, 2026, CIRO will repeal currently mandated CSI course-based provisions, to be replaced with new exam-based provisions as part of the CIRO Proficiency Model for Approved Persons under the Investment Dealer and Partially Consolidated Rules9. The Amendment to eliminate the VPP is to align with the parallel implementation of the proficiency model rule amendments of the same date.

5. Implementation of all other Amendments following CSA approval of the Phase 2 rule amendment proposals

Implementing Phases 1 and 2 on a single date requires that we finalize the proposed Phase 2 amendments for public comment prior to seeking CSA approval. As a result, we will need to provide notice of implementation closer to the date the proposed Phase 2 rule amendments are approved by the CSA. The implementation date chosen will take into consideration any implementation issues raised in response to the public comment request for proposed Phase 2 rule amendments, along with any other relevant or timely considerations.

We believe it is important to fully understand the implementation impact of Phases 1 and 2, together, before finalizing a single implementation period.

6. Appendices

Appendix 1 – Clean copy of the Amendments – Mutual Fund Dealer Rules

Appendix 2 - Blackline comparison of the Amendments to current rules – Mutual Fund Dealer Rules

Appendix 3 - Clean copy of the Amendments - Investment Dealer and Partially Consolidated Rules

Appendix 4 - Blackline comparison of the Amendments to current rules, including proficiency model amendments - Investment Dealer and Partially Consolidated Rules

Appendix 5 - Blackline comparison of the Amendments to current rules - Investment Dealer and Partially Consolidated Rules

Appendix 6 – Summary of public comments received

• 2CIRO Strategic Plan FY 2025-2027
• 3CIRO Annual Priorities for fiscal 2025 | Canadian Investment Regulatory Organization
• 4CSA Position Paper 25-404 - New Self-Regulatory Organization Framework
• 5Bulletin 25-0110 (April 17, 2025)
• 6Rule Consolidation Project
• 7Bulletin 25-0110 (April 17, 2025)
• 8Bulletin 25-0110 (April 17, 2025)
• 9Bulletin 25-0110 (April 17, 2025)