CIRO’s Industry Business Continuity Planning Test – October 25, 2025 – Save the Date

Overview

CIRO has scheduled the next biennial industry business continuity planning (BCP) trading simulation test for Saturday October 25, 2025.

As with the previous industry BCP tests in 2019, 2021 and 2023, the date coincides with industry test dates in the United States to facilitate participation by market participants who participate in both the Canadian and U.S. markets.

Background and purpose

The industry-wide Business Continuity Planning (BCP) test underscores the critical importance of ensuring that stakeholders effectively test their BCP policies and procedures. These policies must be reasonably designed to support the delivery of key services and ensure prompt client access to their assets in the event of a disruption.

The industry BCP test provides the Canadian capital markets community with an opportunity to demonstrate its ability to recover from a significant disruptive event. This test is conducted in accordance with section 12.4.1 of National Instrument 21-101: Marketplace Operation (NI 21-101), which mandates that:

“A marketplace, recognized clearing agency, information processor, and participant dealer must participate in all industry-wide business continuity tests, as determined by a regulation services provider, regulator, or in Québec, the securities regulatory authority.”

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. These rules require every Dealer Member to establish and maintain a BCP that outlines the necessary procedures to be followed during an emergency or significant business disruption.

Information about the 2025 exercise

Similar to the 2023 simulation, participant dealers with annual trading volumes at or above 1 billion shares (based on 2024 trading data) will be required to participate in the trading simulation. All other participant dealers are encouraged to join voluntarily as their involvement will help assess the resilience of the entire system while also testing their own internal capabilities.

In addition to the trading simulation, two additional tests will also be conducted on separate dates, with further details to be provided in the coming months:

• an Incident Response Plan exercise. Developed in collaboration with the Canadian Securities Administrators, this hands-on simulation-based exercise is designed to test incident response planning.
• A crisis communication test will also be undertaken.

Next steps

CIRO staff will contact all participant dealers in April 2025 to confirm their required level of participation in the 2025 industry BCP test.

In the coming weeks, CIRO will also establish an industry working group to provide guidance and support in preparing for the test.

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

If you have any questions about the test or the exercise, please contact MembershipServices@ciro.ca.