In a few months’ time, Canadian investment dealer personnel will have to follow a new proficiency framework, established and maintained by the Canadian Investment Regulatory Organization (CIRO).
It’s the result of a multi-year initiative undertaken by CIRO, formerly the Investment Industry Regulatory Organization of Canada, to enhance its proficiency regime.
“We felt the need to provide a more modern and flexible regime in order to ensure high proficiency standards,” said Elsa Renzella, senior vice-president, enforcement and registration with CIRO.
Renzella said CIRO wants to ensure “that incoming registrants have the necessary knowledge, skills and behaviours that are relevant to their specific roles in the industry.”
As part of the overhaul, the self-regulatory organization is eliminating mandatory courses as prerequisites to exams and shifting to an assessment-centric approach.
This means people won’t be required to take certain courses before writing exams to become a registered representative or portfolio manager, for example.
The new model includes 11 registration categories, which are broken down further based on the products reps are authorized to sell and the clients they’re able to serve. There are nine exams in total, of which aspiring registrants need to take at least one.
For each exam, CIRO plans to publish a syllabus and practice exam. It will also provide guidance to candidates on how to study for each. So far, the regulator has released these materials for one, the Canadian Investment Regulatory Exam (CIRE). It plans to do the same for the remaining eight exams in the coming months.
The new model gives different types of learners a choice in how to prepare for exams, “without tying them down to a specific course,” Renzella said.
“Some people may want to engage in self-study. Others may want the more traditional route of textbooks,” she explained. “Others may leverage technologies that are present everywhere to help them with their studies as well. Or they may take the formal education route through university courses.”
CIRO has partnered with Fitch Learning to facilitate the exam-based model, beginning in 2026.
CSI partnership winding down
The new approach comes as CIRO’s arrangement with the Canadian Securities Institute (CSI), which has provided financial services education and training in Canada for decades, is set to expire at the end of 2025. CIRO has said it’s “working with the CSI to ensure a smooth transition to the new model.”
If an individual is seeking registration before the new proficiency regime takes effect, they have until Dec. 31, 2025 to enroll in courses that are currently available through CSI, “and they are allowed a full year following that to successfully complete those requirements under the current regime,” Renzella said.
A breakdown of the requirements for individuals seeking registration before 2026 is available on the CIRO website.
The new assessment-centric approach is expected to be more affordable.
“There is currently a significant cost to take these current courses and exams, and so we wanted to address that issue, … reducing barriers for candidates coming into the industry,” Renzella said.
The organization has yet to determine the costs associated with each registration category.
“You’ll have that information later in the year, obviously before the Jan. 1 launch date,” Renzella said. “But we can say now that we’ve eliminated the mandatory course requirement, there will be a reduction in costs in general.”
Mandatory conduct training
All registrants — current and new — are required to take mandatory code-of-conduct training under the new proficiency regime. That training’s currently in development.
New registrants approved after Jan. 1, 2026 will have 30 days from the date of their approval to complete the conduct training. Current registrants have to complete the training by the end of 2026.
The code-of-conduct training will count toward registrants’ mandatory continuing education (CE) requirements for that year.
Dealers must notify CIRO once an individual has completed the mandatory training.
If a registrant has not completed the mandatory code of conduct training before these deadlines, CIRO will automatically suspend them. Once they’ve completed the training and their dealer has notified CIRO of completion, the regulator will lift the suspension, and the registrant will be reinstated.
CE requirements
CIRO is revamping CE requirements to ensure that registrants are up to date on industry changes, which could “be anything from professional development, to a specific rule change, to industry development,” Renzella noted.
“That speaks to our need and our desire to keep things current,” she said.
Registrants will be required to complete a certain course, session or program each year to stay on top of their CE requirements. Code-of-conduct training will be the first requirement.
“We haven’t obviously decided on what subsequent topics will form part of the mandatory CE. That will be an iterative and ongoing process,” Renzella said.
Prerequisite education, experience requirements
New registrants will also have to meet baseline education and experience requirements, both of which CIRO has yet to finalize.
“We’re not itemizing specific degrees,” Renzella said. “It will be assessed by our team, but we’re going to provide guidance to the firms.”
Those requirements are slated to be published on CIRO’s website by this summer, she said.
What current registrants need to know
Aside from the code-of-conduct training and subsequent CE requirements, current registrants will be exempt from the new proficiency requirements as long as they remain in their current roles without a break exceeding 180 days.
If a registrant returns to a dealer within the 180-day period, but to an approved person category that requires different baseline proficiencies, they will not qualify for an exemption from the new requirements.
Individuals seeking reapproval after leaving their roles for more than 180 days will be exempt from having to complete the CIRE, provided they have at least two years of experience in the same registration category within the last three years.
If an individual takes a leave of absence, they will be deemed to have remained in the same role. But they will still be required to complete their CE requirements and ongoing training under the new proficiency regime. A dealer, on behalf of an individual, may consider whether they should apply for a discretionary exemption.
CIRO is also transitioning to single derivatives product proficiencies, meaning the product types of options, futures contract and futures contract options will be consolidated into one product type to capture all derivatives.
Current registrants who trade only in options or futures will be able to continue to do so once the new rules are implemented, under the newly created options (legacy) and futures (legacy) product categories, per the Canadian Securities Administrators’ National Registration Database. These registrants will not be required to take the new CIRO exams, including the derivatives exam, unless they wish to deal in all derivatives.
“We appreciate the significance of the changes happening,” Renzella said. “We will be seeing a lot of information roll out between now and Jan. 1, and we are reaching out to key stakeholders, including education providers, member firms and the general public, so they understand what they need to take if they’re interested in entering the industry, the cost involved and any guidance in terms of what they need to do to prepare for the new program.”
— With files from James Langton