The Canadian Investment Regulatory Organization (CIRO) is nearing the end of phase six of its consolidated rulebook, an initiative intended to complete the amalgamation of Canada’s two dealer self‑regulatory organizations and enhance investor protection. A core promise of this effort has been harmonization: ensuring that similar activities are subject to similar regulatory requirements across the country.
Yet when it comes to complaint handling timelines — one of the most basic and investor-critical elements of the regulatory framework — CIRO has neglected that promise.
CIRO and its predecessor, the Investment Industry Regulatory Organization of Canada, have repeatedly consulted on complaint‑handling timelines. With the phase six rule consolidation, complaint‑handling timelines will have been reviewed through at least four separate consultation processes. Despite this extensive engagement, no national improvements have resulted.
In contrast, Quebec’s Autorité des marchés financiers (AMF) acted quickly. After two rounds of public consultation, the AMF implemented new requirements effective July 1, 2025. Firms must now give a final response to most client complaints within 60 days, with extensions to 90 days allowed only in exceptional circumstances.
This requirement applies to CIRO member firms operating in Quebec and reflects the AMF’s long-standing view that prompt complaint resolution is essential to fairness, confidence and market integrity.
That perspective is hard to deny. For investors risking financial loss, long complaint processes heighten stress and uncertainty and can worsen harm, especially for seniors and other vulnerable clients. In this context, complaint‑handling timelines relate to the integrity of the redress process itself, not just internal operational efficiency.
Given CIRO’s stated commitment to harmonization, it would have been reasonable to expect it to adopt the 60‑day standard. From a public‑interest perspective, it is difficult to justify why an investor in Halifax, Calgary or Vancouver should wait longer for a response than an investor in Montreal.
Instead, CIRO is maintaining a two‑tier system. In Quebec, firms are required to meet the 60‑day standard. Elsewhere, the outdated 90‑day timeline remains in effect.
Outside Quebec, provincial securities legislation still reflects a 90-day complaint-handling standard. While there is a strong case for the Canadian Securities Administrators (CSA) to revisit their legislative requirements, CIRO should not treat this as a reason for inaction.
Unlike the CSA, CIRO directly oversees firms that interact with the majority of retail investors. Had it chosen to adopt the 60-day standard, CIRO could have delivered an immediate and tangible improvement for complainants across the country.
A consolidation exercise
CIRO has stated that phase six was primarily a consolidation exercise rather than an opportunity for substantive policy reform. That position is difficult to reconcile with the scope of the proposals.
The consolidated rulebook introduces meaningful new flexibility for member firms, including permitting mutual fund dealers to offer margin accounts and free credits, and allowing investment dealers to carry mutual fund dealers or permanently license mutual fund dealing representatives.
Against that backdrop, the repeated deferral of investor-focused improvements to complaint-handling timelines — despite years of consultation — stands out. CIRO routinely exceeds baseline CSA requirements in other areas, including capital and proficiency. The decision not to do so here reflects an absence of leadership that warrants closer scrutiny.
In this instance, investor interests appear to have been subordinated, raising broader concerns about the credibility of the self-regulatory organization (SRO) model as a public-interest framework.
Support for a 60-day timeline
When the CSA approved the SRO amalgamation, it emphasized stronger public‑interest safeguards at CIRO, including increased independent board representation and the creation of an Investor Advisory Panel (IAP). These mechanisms were intended to ensure that investor perspectives would meaningfully influence decisions, particularly where industry pushback was foreseeable.
CIRO’s IAP strongly supported adopting Quebec’s 60‑day timeline, as did many other stakeholders. Nevertheless, the phase six proposals preserve an unharmonized approach. Where formal investor feedback does not translate into policy outcomes on issues of this significance, it is reasonable to question whether the promised governance enhancements are functioning as intended.
Complaint-handling timelines are not abstract regulatory details. They determine how long investors wait for answers, resolution and access to redress. Extended timelines risk undermining confidence not only in individual firms, but also in regulators and in the perceived fairness of Canada’s capital markets.
CIRO has had multiple opportunities to align its framework with a higher standard that their firms must comply with in Quebec. Adopting Quebec’s 60-day approach would have been consistent with CIRO’s stated principles and its public-interest mandate.
Responsibility now rests with CIRO’s board and the CSA. At this stage, further consultation or study risks prolonging an issue that has already been examined extensively. A clear directive to implement a consistent and national standard would send a strong signal that harmonization and investor protection are central to CIRO’s regulatory approach. How CIRO resolves this issue will be an important test of its public-interest mandate.
Jean‑Paul Bureaud is executive director of FAIR Canada.