When the Canadian Investment Regulatory Organization’s (CIRO)
exam-based proficiency regime launched Jan. 1, Canadians seeking investment advice confronted an uncomfortable truth: their advisors now hold credentials that would not qualify them to practice in any recognized profession, yet these individuals guide decisions affecting retirement security for millions.
The organization has framed the changes as modernizing licensing requirements while raising professional standards. A closer examination reveals a system that does more to reduce friction for firms than to move investment advice toward the standards expected of genuine professions.
The regime applies to approved persons of investment dealers under CIRO’s investment dealer and partially consolidated rules. CIRO has replaced mandatory courses with nine exams built on published competency profiles. Candidates pay $475 per exam and may attempt each exam up to three times within a 12-month window.
Entry into a registered representative role requires passing relevant CIRO exams plus either a diploma or degree from an accredited post-secondary institution, or four years of “relevant experience” as assessed by dealers and CIRO staff.
Grandfathering away reform
Most telling is how little the regime asks of the existing workforce. Anyone who was an approved person as of Dec. 31 can continue without completing new exams or meeting new education baselines. All existing advisors must complete a conduct-training module by year-end 2026, but that is the only mandatory uplift.
CIRO deemed the previous course-based system inadequate — hence the overhaul — yet allows all currently licensed advisors to continue indefinitely after completing a short online module.
If proficiency gaps genuinely existed, investor protection would require closing them before automatically grandfathering thousands of practitioners. Instead, higher standards apply only to future entrants — a tacit admission this is about modernizing licensing infrastructure, not elevating professional competence.
Compare this to recognized professions. Lawyers in Ontario require an undergraduate degree, three years of law school, licensing exams and 10 months of structured articling. Engineers need an accredited engineering degree, four years of supervised experience and a professional practice exam. Chartered Professional Accountants must complete prescribed education and pass the common final examination, where recent pass rates have ranged from the high-60s to mid-70s.
CIRO’s model offers none of this. While requiring a “relevant” post-secondary credential, CIRO has deliberately avoided defining what qualifies as relevant. The organization confirms it will not mandate “specific types of education,” leaving dealers and staff to assess acceptability case by case.
In practice, a degree in any discipline — medieval history, physical education or fine arts — paired with passed exams suffices. No recognized profession allows such flexibility: law requires a law degree, engineering requires an engineering degree, accounting requires accounting education.
No mandatory pre-licensing education
Most significant is CIRO’s elimination of mandatory pre-exam course work. Candidates can now sit licensing exams without completing any prescribed education program.
CIRO has committed to publishing competency profiles, exam blueprints and study guides. These materials are useful, but they are not substitutes for structured, accredited education.
With no mandatory courses and no accreditation of preparatory programs, Canada is now relying on a fragmented exam-prep market. In that kind of market, the commercial incentive is to focus on helping candidates get over the pass mark rather than building the broader competence needed to advise on retirement savings.
Imagine permitting anyone with any undergraduate degree to self-study for medical licensing exams, then practice surgery upon passing — no medical school needed, no supervised residency, just study materials and a test.
The public would never accept surgeons credentialed this way. Yet Canadians are expected to entrust their retirement security — often their only protection against poverty in old age — to advisors licensed through precisely this model.
CIRO has published no pass-rate targets, exam difficulty benchmarks or performance data demonstrating these exams filter for competence. The organization studied CPA Canada’s common final exam and the CFA exams (which has a program pass rate under 50%), but has set no comparable selectivity standards. Without published performance metrics, investors have no basis to assess if CIRO’s exams represent meaningful gatekeeping.
The experience alternative
CIRO’s alternative pathway allows approval based on four years of “relevant experience” alongside prescribed exams. But dealer environments — with proprietary products, sales quotas and embedded conflicts — cannot reliably replicate structured professional training.
A junior advisor pushing high-fee mutual funds gains “experience” CIRO might accept, yet learns nothing about fee-based planning, fiduciary obligations or independent advice models. Genuine professions require both discipline-specific education and supervised practice — never experience alone as substitute for foundational learning.
CIRO has no published code of conduct for advisors — a feature standard in recognized professions and required under Ontario’s Financial Professionals Title Protection Act for credentialing bodies. Investors cannot reference clear standards of professional responsibility because none are publicly articulated beyond scattered rules and guidance.
CIRO has modernized licensing logistics without establishing professional standards. Most advice will continue to be delivered by individuals whose credentials would not qualify them for any recognized profession.
CIRO could still strengthen this framework: attach specific education requirements to advisory roles, accredit pre-licensing programs, publish exam performance data demonstrating genuine selectivity and require transitional upgrades for grandfathered advisors.
Until then, understand CIRO’s proficiency regime as it operates: a more efficient licensing system for dealers, not the professionalization of financial advice in Canada.
