Guidance on the CIRO Investment Dealer Continuing Education Program

1. The CE Program

1.1 Overview

CIRO has a mandatory investment dealer (ID) CE Program to ensure that applicable Approved Persons under the IDPC Rules remain current on industry and regulatory developments. The continuing education rules are set out in the IDPC Rule 2700 (CE Rules).

The ID CE Program operates in two-year cycles (CE cycle) and consists of a Compliance course requirement, a Professional development (PD) course requirement and mandated annual continuing education training specifically prescribed by CIRO.4

CE cycles start on January 1^st of the first year of the CE cycle and end on December 31^st of the second year of the CE cycle.

1.2 Compliance course requirement

Clause 2703(1)(i) sets out the requirements for the Compliance course. A Compliance course must fall within at least one of the following three major topic areas:

• Ethical issues,
• Regulatory developments, and
• Rules governing dealer

Refer to Appendix A for a list of suggested topics that satisfy the Compliance course requirement.

1.3 PD course requirement

All training that fosters learning and development in areas relevant to dealer business may qualify as a PD course for CE credit.5 This includes PD training that is part of a Canadian or foreign course. It also means an individual could take CIRO exams in preparation for and advancement of his or her professional growth and development in future roles. The PD guidelines, found in Appendix B, detail broad topics for consideration when choosing a PD course.

1.4 Mandated annual continuing education

As of January 1, 2026, CE Participants must complete 1 to 3 hours of annual mandated CE training as prescribed by CIRO to ensure that they keep up to date with those matters which we find are of utmost importance in a given year. Mandated CE hours will be hours to be completed within the total required CE credit hours, not more.

Each year, CIRO will determine the number of hours and the type of credit (i.e., either compliance or professional development) to be completed for mandated CE training in advance of the CE training. For general CE reporting requirements, see also section 9.2.

Note, for the first year of the new requirement, in 2026, CIRO will prescribe completion of the Mandatory Conduct Training6 as the applicable CE training requirement, as discussed in section 4.4 of Bulletin 24-0206. The training will count for 3 Compliance course credits. In addition, for the first year, a Dealer is expected to report individual completion of the Mandatory Conduct Training, in NRD, by the deadline prescribed in subsection 2604(2), and also in CIRO’s CE online reporting system, CIRO Services, by December 31, 2026.

1.5 CIRO’s course accreditation process

In accordance with subsection 2703(3), the Dealer or external course provider may provide CE courses. Dealers or external course providers may accredit their CE courses through CIRO’s accreditation process as described in Bulletin 21-0196.7

The list of accredited courses is located on ciro.ca.

1.6 Exemption from part of the CE Program

Certain individuals continuously approved in a trading capacity since January 1, 1990 or earlier are exempted from the PD course requirement.8 These individuals are required to complete only the Compliance course requirement of the CE Program. To maintain the exemption status, an individual must have been continuously approved in a trading capacity and may not have a break in approval of more than 90 days.

1.7 Course repeats

CE Participants cannot claim CE credits for the same CE course if they have completed the course before, unless the course contains new course content.9 A change in the name or date of the course alone from one year to the next year, for example, would not be sufficient and does not qualify as new course content.

2. ID CE Requirements

2.1 Requirements based on Approved Person category

The following Approved Person categories at an investment dealer are required to complete a minimum of 10 hours of the Compliance course requirement:

• Associate Portfolio Manager (APM),
• Portfolio Manager (PM),
• Registered Representative (RR) (retail/institutional),
• Investment Representative (IR) (retail/institutional),
• Supervisor,
• Trader,
• Chief Compliance Officer (CCO), and
• Ultimate Designated Person (UDP).

APMs, PMs and RRs (retail) must complete an additional 20 hours of the PD course requirement in each CE cycle.10 No other Approved Person categories are required to complete CE.

A CE Participant may be approved in more than one Approved Person category. CIRO requires CE Participants to complete the CE requirements for the category with the more onerous requirements. For example, where an individual is approved as a RR and a CCO, CIRO will require the CE Participant to complete both the Compliance and PD course requirements for the RR category.

An individual suspended for failure to meet their CE requirements may be reinstated after completing their CE requirements.11 Similarly, an individual who was suspended for failure to complete their post-approval requirements and did not complete their Compliance course requirement is also required to complete this prior to reinstatement in the next cycle. Dealers employing individuals under suspension who have not met their requirements will be subject to the penalties described in section 10.

2.2 Courses recognized for CE

CE courses may include a single, integrated course or series of relevant courses, seminars, programs or presentations that together meet the time and content requirements for continuing education set out in Rule 2700.12 CE Participants can meet their CE requirements from a variety of sources. Courses chosen for CE must be approved by the Dealer and meet the requirements under the CE Rules.

For example, subject to the Dealer’s approval, CE Participants may meet their CE requirements by successfully completing:

• a Compliance or PD course from a Dealer or external course provider, whether or not the course has been accredited by CIRO,
• a Compliance or PD webcast, seminar, other public event hosted by CIRO or another regulator, or
• other qualifying alternate activities as listed on Appendix C.

2.3 Courses accredited for both Compliance and PD credits

Courses accredited by CIRO for both Compliance and PD CE credits may be used for either Compliance or PD CE credits, up to the maximum CE credit value of the course. For example, an individual who completed a 5-hour course approved for both Compliance and PD, could allocate 2 hours to PD and 3 hours to Compliance, or in any other combination, up to a total of no more than 5 hours of CE. These courses are identified with a CP at the end of their accreditation number.

However, if the course is specifically accredited for 3 hours of PD and 2 hours of Compliance, a CE Participant would only be able to allocate up to a maximum of 3 hours of PD and 2 hours of Compliance CE. These courses are identified with separate accreditation numbers, one with a P and the other with a C at the end of their accreditation number.

2.4 CIRO exams

As set out in subsection 2701(1), a guiding principle of CE is to enhance and further develop an individual’s baseline proficiencies. As of January 1, 2026, CIRO baseline proficiencies include CIRO exams required under IDPC Rule 2600. CE is meant to build upon these fundamentals.

A CE Participant may use a CIRO exam for CE if the exam they completed enhances and further develops their baseline proficiencies, subject to approval by the CE Participant’s Dealer. Any CIRO exam completed prior to being a CE Participant will not qualify towards CE credit hours.

Completed CIRO exams are eligible for CE. Subject to a Dealer’s approval, a CE Participant who wishes to use a complete CIRO exam may claim up to the equivalent of the allotted time to complete the exam. For example, an exam that last 1.5 hours is eligible for 1.5 CE credit hours.

2.5 Recognition of CE requirements of other regulated platforms

The CE Rules recognize a broad range of Compliance and PD training topics. As such, individuals are allowed to use courses offered by other regulated platforms and organizations for CE credit if:

• the course meets requirements of section 2703,
• subject to the Dealer’s approval, and
• subject to any other requirements under the CE Rules.

For example, a CE Participant that completes a course to meet their CE requirements of another regulated platform, such as financial planning or insurance, may also use that course towards their CE requirements under CIRO’s ID CE Program, if approved by the Dealer and if the course meets the requirements to qualify as a CE course under the CE Rules.

2.6 CE credit for foreign compliance courses

Five hours of a CE Participant’s Compliance course requirement may consist of CE compliance courses offered by a foreign securities dealer or foreign external course provider.13

For example, a CE Participant who is also registered with the Financial Industry Regulatory Authority (FINRA) as a General Securities Representative may use up to 5 completed hours of FINRA’s required CE Regulatory Element to satisfy the ID CE Compliance course requirement in the same CE cycle.

3. CE Program Courses and Administration – The Compliance course

3.1 Dealer compliance manual training

There is a broad spectrum of approaches taken by Dealers to fulfill Compliance course requirements. Many Dealers develop Compliance courses that are customized to their own business, the employee conduct they desire, and on issues and developments they wish to focus on. CIRO views this as valuable CE.

Following the principle that CE enhances and further develops an individual’s baseline proficiencies, in circumstances where the Dealer is using its compliance manual for that specific training to be eligible for CE credit, we require that the compliance manual training expand on the content in the manual and cover ethical issues, regulatory developments and rules governing dealer conduct. CIRO will recognize compliance manual training delivered by the Dealer through in-person seminars or webinars that are accompanied by a method of evaluation.14 Reading the compliance manual alone does not qualify for CE credit.

3.2 Ethics course

The CE Rules seek to encourage development of ethics training resources by Dealers and external course providers. Although the same course may not typically be repeated for CE unless the course contains new content, CE Participants may repeat CIRO approved ethics courses and count them towards their compliance course requirements in two CE program cycles, which do not need to be consecutive.15

CIRO will assess whether a course qualifies as an CIRO approved ethics course through our review of applications for accreditation of CE compliance courses. To qualify as an ethics course, the content in the course should relate principally to ethics, ethical conduct, professionalism, and professional responsibility. Courses should be relevant to the dealer business.

CIRO will indicate which courses qualify as an CIRO approved ethics course on CIRO’s listing of accredited courses.

4. CE Program Courses and Administration – The PD course

As of January 1, 2026 CE Participants will no longer be allowed to carry forward PD CE credits into the next CE cycle. Instead, a CE Participant subject to the PD course requirement may only receive CE credit for a PD course with an examination, only if the continuing education participant successfully passes the examination.16

5. Dealer’s Administration of the CE Program

5.1 Supervision and approval of CE Participants’ courses

Dealers must designate an individual responsible for supervising training and approving a CE Participant’s chosen CE courses. We do not require this individual be approved as a Supervisor, unless the individual performs other activities which require them to obtain CIRO approval as a Supervisor.

Dealers must ensure that their CE Participants’ chosen CE courses comply with both the Compliance and PD course requirements set out in subsection 2703(1).17

Dealers should establish internal procedures for assessing courses for CE credit. Courses should be evaluated using the Compliance course and PD course requirements set out in the CE Rules, and corresponding guidelines found in the Appendices to this guidance as reference. Dealers may consider a streamlined review for courses that have been accredited by CIRO for CE.

5.2 Dealer’s program

Provided below is a suggested process for a Dealer to apply when establishing its own CE courses:

(1) Identify training needs, including:

• Knowledge and skills, which would impact positively on the Dealer and CE Participants, and
• Learning objectives expected from the program or

(2) Identify the evaluation method or methods to be

Dealers are required to evaluate CE Participants’ knowledge and understanding of the course. CIRO does not require Dealers to use a specific method of evaluation or testing for CE courses. However, Dealers should choose an evaluation method that is appropriate given the course’s delivery method and learning objectives. Examples of an appropriate evaluation method may include:

• an examination or quiz,
• course work,
• a case study, or
• workshop

(3) Determine how successful completion is to be

Dealers should use reasonable judgement to determine what constitutes successful completion of an internally delivered CE course. Examples can include the following:

• If the course includes an examination, the CE Participant would need to successfully complete that examination. The Dealer may require the CE Participant to correctly answer a minimum number of questions to pass.
• For a lunch and learn, the Dealer may consider requiring the CE Participant to sign in, actively participate, and stay for the entire session before the Dealer can issue a certificate of attendance.
• For a webinar, the Dealer may consider requiring the CE Participant to solve a problem or complete a case study online prior to receiving a certificate of completion.

(4) Identify the delivery mechanism or mechanisms by:

• Determining the most appropriate delivery method,
• Determining which internal experts are capable of providing delivery material, and
• Identifying programs or courses that would deliver the skills and knowledge which would meet the Dealer and CE Participant’s

(5) Verify desired

Dealers may want to periodically review internally delivered courses for continued effectiveness in meeting its training needs.

5.3 Courses completed at former sponsoring Dealer

A Dealer may allow a CE Participant to use the CE credits earned through courses or seminars completed at the CE Participant’s former sponsoring Dealer and may accept a statement of completion issued by the CE participant’s former sponsoring Dealer.18 The CE Participant may need to provide proof of successful completion and is responsible for providing the required documentation for their new Dealer’s assessment.

6. Participation in the CE Program

6.1 Participation of Approved Persons

CE should be timely and ongoing. An individual enters the CE Program cycle as a CE Participant upon approval in an Approved Person category with CE requirements.19

Where approval occurs in the last six months of a CE cycle, the individual will be subject to CE requirements in the following CE cycle. This does not permit individuals who were previously approved in a category with the same or lesser CE requirements from avoiding those CE requirements when they return in the same CE cycle. Examples are provided below in paragraph 7.1.

7. Changes during a CE Program Cycle

7.1 Changes to Approved Person category

A CE Participant that changes Approved Person categories during a CE cycle is required to complete the CE requirements of his or her new Approved Person category.20

If the change in category occurs in the last six months of the CE cycle, the CE Participant’s requirements will be as follows:

• If the change in category results in the same requirements, or the individual is reactivating or reinstating in the same category, the CE Participant remains subject to the CE requirements for the new category. For example, the CE participant was an RR and changed to a PM category in the last month of a cycle, they would be required to complete the CE requirement (compliance and PD) for the PM category in the current CE cycle.
• If the change in category results in an increase to the CE Participant’s CE requirement, the CE requirement is for the previous position in the current CE cycle. The new additional requirements will begin in the following CE cycle. However, if the CE Participant was previously approved in the same CE cycle in a category requiring the higher requirements, they would be subject to the higher requirements immediately. For example, a CE Participant changes category from an IR to RR in the last month of the CE cycle. As a result, the CE Participant is required to complete the CE requirement for the IR position in the current CE cycle. In the following CE cycle, the CE Participant will be subject to the CE requirements (compliance and PD) for the RR category. However, if the CE Participant was approved as a RR earlier in the cycle, and then changed to IR, and then changed back to RR in the last six months, they would be subject to the RR requirements in the current CE cycle.
• If the change in category results in a decrease of the CE Participant’s CE requirement, the CE Participant is immediately subject to the CE requirement of their new Approved Person category. For example, the CE Participant was an RR and changed to an IR in the last month of the CE cycle. The CE Participant would only be required to complete the CE requirement for the IR category (compliance CE only) in the current CE cycle subject to the information provided to CIRO as described below.

To ensure the CE Participant’s change in category is not done to avoid completing a CE requirement, the Dealer must provide CIRO with a letter of explanation.21 The letter should explain the reasons for the change in category and confirm that the change is not a deliberate attempt to avoid a CE requirement. CIRO Registration staff may request additional information if the explanation is not satisfactory. Similarly, if in the first six months of the following cycle the CE Participant changes back to a category that requires both Compliance and PD course requirements, the Dealer will need to provide CIRO with another letter of explanation.

8. Discretionary Relief

8.1 Extensions to complete CE requirements

A Dealer may seek an extension to complete CE requirements on a CE Participant’s behalf. Extensions may be requested in circumstances where an individual requires more time to complete their CE requirements due to, but not limited to, an illness or other hardship. Extension requests must meet the requirements under subsection 2745(1).

Generally, CIRO will support extension requests for up to the lesser of six months or the length of the CE Participant’s absence. Extensions greater than six months, or for a period longer than the CE Participant’s absence may be granted in limited situations. All requests are decided on a case-by-case basis.

Any extensions granted will not result in additional time allotted to the CE Participant to complete their CE requirements in the following CE cycle. In other words, if the individual faces a hardship in completing their CE requirements during the next CE cycle, a separate request and submission will be required.

8.2 Exemptions from CE requirements

All CE Participants, including those on a leave of absence, must complete their CE requirements each cycle to maintain the currency of their proficiencies and Approved Person status. Failure to do so may result in fines and/or suspension as outlined in section 2755.

A Dealer may seek an exemption from CE requirements on a CE Participant’s behalf where the CE Participant is on an indefinite leave of absence and unable to complete their CE requirements due to, but not limited to an illness, for more than one CE cycle. These requests must meet the requirements under subsection 2745(2). Exemption requests should be supported by reasons indicating the nature of the hardship faced. Submissions are reviewed on a case-by-case basis.

A CE Participant who is granted an exemption under subsection 2745(2) and then returns:

• after an absence of three years or less must have CIRO determine the CE requirements before they resume any activity that needs approval, or
• after an absence of more than three years, then they must meet the applicable proficiency and registration requirements for their Approved Person category.22

9. Record keeping, reporting and penalties

9.1 Record keeping requirements

Dealers must keep evidence and verify their CE Participants’ successful completion of the CE courses.23 This may take the form of course certificates or notices of completion issued by the internal or external course provider.

Dealers must retain CE records for a minimum of seven years, following the end of the CE cycle.24 CIRO may audit a Dealer’s CE records to ensure compliance with the CE Rules.

9.2 Reporting requirements

Dealers must notify CIRO of its CE Participants’ CE completions within 10 business days after the end of the CE cycle. Dealers are required to update this information in CIRO’s CE online reporting system located in CIRO Services.25 Dealers may also report CE completions, at any time, throughout the CE cycle for operational efficiency.

Dealers can also use the CE online reporting system to conduct searches and generate completion status reports that show which CE Participants at the Dealer have not completed their CE requirements.

We expect Dealers to use the CE online reporting system to verify their records for CE completions. Where a CE Participant has not completed their CE requirements, we expect the Dealer to follow up and inform them that a CE Participant with incomplete and unreported CE requirements will face suspension on the last business day in the first month of the next CE cycle. For example, for CE cycle 9, (which ran from January 1, 2022 to December 31, 2023) the last business day in the first month of CE cycle 10 was January 31, 2024.

Dealers who require technical assistance with CIRO’s CE online reporting system should contact investmentdealerCE@ciro.ca.

9.3 Penalties

CIRO will impose the following penalties on Dealers who fail to meet their CE reporting requirements and/or for non-completion of CE requirements by the Dealers’ CE Participants:26

• $100 fee for each business day of CE non-completion or late filing for each CE Participant. CIRO will begin to impose fees on the 11^th business day after the end of the CE cycle. This daily fee will continue up until the Dealer reports to CIRO that the CE Participant’s CE requirements are complete, or until the last business day of that month, whichever comes later, and
• If on the last business day of the first month of a CE cycle, the Dealer has not reported that a CE Participant has completed their CE requirements, CIRO will suspend the CE Participant’s approval. The CE Participant will be required to cease all registerable activities immediately.

9.4 Request to lift suspension

CIRO may reinstate a CE Participant’s approval after they have completed their requirements and their Dealer has notified CIRO in writing.27

To make this request, we ask that the Dealer notify their CIRO Registration Manager or Senior Registration Officer in writing, by email, indicating that the CE Participant has completed their CE requirements and requests removal of the suspension. We may request supporting documentation such as proof of completion of any CE courses prior to lifting the suspension.

10. Applicable Rules

This Guidance Note relates to IDPC Rule 2700.

11. Previous Guidance Note

This Guidance Note replaces GN-2700-21-001 – Guidance on IIROC’s Continuing Education Program.

12. Appendices

CIRO provides guidelines for its ID CE program to assist individuals and Dealers understand and comply with the CE Rules.

These guidelines have been developed to provide flexibility to Dealers and CE Participants.

Below are guidelines for the following elements of the CE Program:

• Appendix A - Compliance Course
• Appendix B - PD Course
• Appendix C - Alternate Activities

Appendix A – Compliance Course

Clause 2703(1)(i) describes the Compliance course requirement for the ID CE Program. Examples of relevant topics include:

1. Securities laws, regulations, and proposed changes
2. Disclosure of information to clients
3. Conduct standards
4. Supervisory responsibilities
5. Operations and Dealer capital
6. Effective compliance programs
7. Current developments in bond market regulation
8. Suitability and new products
9. Corporate finance – new and proposed rules
10. Ethical issues and practices in the securities industry
11. Conflicts of interest
12. Professional responsibility
13. Risk management techniques
14. Consequences of non-compliance in the securities industry
15. Anti-money laundering and terrorist financing for securities industry professionals
16. Ethical practices in the securities industry
17. Regulatory developments that affect Dealer management
18. Corporate governance
19. Use of social media and technology
20. Know your product
21. CRM2
22. Cyber security
23. Best interest standard
24. Privacy legislation
25. Sales and trading – institutional markets
26. Screening for suitable clients

Appendix B – PD Course

Clause 2703(1)(ii) describes the PD course requirement for the ID CE Program. Suggested topics for training include:

1. Practice management skills
2. Business development skills
3. Communicating with clients – meetings, presentations, written documents
4. Managerial skills
5. Developing sales acumen
6. Training that supports know your product obligations
7. Approaches to valuation of a product category and a product’s applicable risk factors
8. Retirement planning strategies
9. Economic principles that assist in evaluating investment strategies
10. Financial planning strategies
11. Retirement, estate and tax planning strategies
12. Suitability of the use of leverage for a product category/investment strategy
13. Methods of evaluating competing products, services, and investment strategies
14. Technology used to enhance client service and the provision of advice
15. Investment knowledge including investment strategies and understanding of financial markets
16. Portfolio Management practices
17. Enhancing client relationships
18. Client Management practices
19. Dealing with different client demographics, including completing language courses

Appendix C – Alternate Activities

Alternate activities may be used to satisfy CE credit hours upon request. These activities will not be included on the CIRO accredited course listing.

CE Participants who are members of CIRO advisory committees, who participate in CIRO working groups or training, and attend CIRO conferences may be able to use their participation in these activities towards CE credit hours. Requests are to be made to the CIRO coordinator responsible for the particular committee/conference. Below is a non-exhaustive list:

1. Conduct, Compliance and Legal Advisory Section (CCLS) meetings
2. Proficiency Committee meetings
3. Fixed Income Committee meetings
4. Market Rules Advisory meetings
5. Financial and Operations Advisory Section (FAS) meetings and conference
6. National and Regional Council meetings
7. Hearing Committee training

CE Participants may also use other alternate activities towards their CE credit hours such as those shown in the non-exhaustive list below. Requests are to be made directly to their Dealer for consideration if the activity can be used towards the CE Participants’ CE requirements.

1. Teaching courses related to dealer business
2. Writing books or articles related to dealer business
3. Presenter at a conference/seminar/webinar related to dealer business
4. Completing a course at a university or college related to dealer business

• 4Subsection 2703(1)
• 5Clause 2703(1)(ii).
• 6Subsection 2604(2)
• 7Subsection 2703(4).
• 8Subsection 2703(5).
• 9Subsection 2703(6).
• 10Subsection 2704(1)
• 11Subsection 2755(3) specifies that IIROC may reinstate the CE Participant’s approval after the sponsoring Dealer has notified CIRO in writing that the CE Participant has completed their CE requirements.
• 12Subsection 2702(1)
• 13Clause 2715(1)(iii).
• 14Subsection 2715(2).
• 15Subsection 2715(3).
• 16Subsection 2716(1)
• 17Clause 2717(1)(v).
• 18Subsection 2717(2).
• 19Section 2725.
• 20Section 2735.
• 21Subsection 2735(3).
• 22Subsection 2745(3).
• 23Clauses 2717(1)(i) and (ii).
• 24Clause 2717(1)(ii).
• 25Clause 2717(1)(vii).
• 26Subsections 2755(1) and (2).
• 27Subsection 2755(3).