CIRO Exemptive Relief in 2025: Key Themes for Dealers and Approved Persons

CIRO Exemptive Relief: Top Takeaways

• CIRO continues to use exemptive relief to address practical regulatory challenges, particularly where alternative safeguards can achieve the underlying regulatory objective.
• The 2025 exemptions covered several recurring areas, including UMIR trading activities, dual registration, crypto asset activities, securities lending, account administration and proficiency requirements.
• Dealer Members should review prior exemption decisions to identify potential relief opportunities and anticipate the conditions CIRO may impose.
• Applications for relief should demonstrate how alternative controls will achieve the underlying investor-protection or market-integrity objective.

On August 10, 2026, CIRO published its annual summary of exemptions granted in 2025, illustrating how exemptive relief continues to serve as an important mechanism for regulating Dealer Members and addressing practical challenges arising under the Investment Dealer and Partially Consolidated Rules (“IDPC Rules”), Mutual Fund Dealer Rules (“MFD Rules”) and Universal Market Integrity Rules (“UMIR”).

The decisions also provide useful insight into CIRO’s approach to balancing regulatory flexibility with investor protection, market integrity and the interests of Dealer Members, Approved Persons, and their clients.

Why It Matters

CIRO may grant exemptive relief where the CIRO Board or staff is satisfied that the relief would not be prejudicial to the public interest, clients or Dealer Members, as applicable. Relief may also be subject to conditions, reporting obligations, enhanced supervision or a specified expiry date.

The 2025 exemptions demonstrate that relief is generally tailored to the particular facts and regulatory objectives at issue. They should not be viewed as broad waivers from CIRO requirements or as substitutes for compliance planning, but do provide insights into common exemptions that CIRO may grant.

Dealer Members should review prior exemptions granted by CIRO to better understand the practical challenges faced by other firms, assess whether similar relief may be available and desirable in comparable circumstances, and anticipate the types of conditions CIRO may impose when granting exemptive relief.

Principal Categories of Relief

The exemptions granted during the year covered several recurring areas, including:

• UMIR trading exemptions: CIRO staff granted relief in circumstances involving off-marketplace transactions, intentional crosses involving a jitney Participant, short position reporting and other transactions where the exemption was considered consistent with the maintenance of a fair and orderly market and would not be prejudicial to the public interest.
• Exemptions from IDPC Rules or MFD Rules granted by the CIRO Board: Relief continued to support Dealer Members operating as both investment dealers and mutual fund dealers within a single legal entity. These exemptions are intended to facilitate the integration of the two business models while addressing differences between the applicable IDPC and MFD requirements. The CIRO Board also granted relief from cross-guarantee requirements, use of an automated order system by order execution only account clients for trades that occur in the United States and fully paid securities lending programs while permanent CIRO rules are being developed.
• Exemptions from IDPC Rules or MFD Rules granted by CIRO Staff: CIRO Staff granted relief from reporting on outside holdings requirements, bulk account movements, account opening timelines, reporting obligations and other operational requirements where strict compliance could create disproportionate practical difficulties without a corresponding regulatory benefit.
• Crypto asset activities: Exemptions relating to mail insurance, custody and capital treatment continued to reflect the distinctive risks associated with crypto asset trading. As with prior relief, the exemptions were subject to conditions which are now prescribed in standard terms and conditions outlined in CIRO’s Digital Asset Custody Framework (see our prior blog, CIRO’s Digital Asset Custody Framework).
• Proficiency and continuing education: CIRO staff granted exemptions, extensions and other relief relating to proficiency examinations and continuing education requirements. The relevant considerations included prior industry experience, education, hardship and whether the applicant’s qualifications demonstrated competencies equivalent to those addressed by the applicable requirements. The majority of applications for proficiency exemptions related to the Canadian Securities Course (CSC), Wealth Management Essentials (WME), Conduct and Practices Handbook Course (CPH), and Partners, Directors and Senior Officers Course (PDO).

A Focus on Proportionality

Taken together, the exemptions suggest that CIRO is applying a principles-based approach to regulation.  Relief may be appropriate where the underlying regulatory objective can be achieved through alternative safeguards, particularly where the applicant can demonstrate that the requested exemption will not materially increase risk to clients or the market.

At the same time, the conditions attached to exemptive relief remain significant. Depending on the circumstances, CIRO may require enhanced supervision, limitations on the scope of the relief, compliance with other regulatory regimes, specified client protections or an expiry tied to a future rule amendment.

This approach is particularly relevant in areas undergoing regulatory change, including dual registration, crypto asset custody, fully paid securities lending and the consolidation of CIRO’s dealer-member rule framework. Temporary relief can assist firms in managing transitional issues while CIRO and the Canadian Securities Administrators develop more permanent rules or guidance.

Practical Considerations

Dealer Members and Approved Persons seeking relief should consider the following:

• Identify the specific rule requirement from which relief is sought and explain why strict compliance is impractical or unnecessary in the circumstances.
• Demonstrate how the proposed alternative controls would preserve the rule’s underlying investor-protection or market-integrity objective.
• Provide detailed information regarding the affected clients, products, accounts, transactions and business processes.
• Anticipate conditions relating to supervision, disclosure, recordkeeping, reporting and periodic review.
• Consider whether the requested relief should be time-limited or tied to the implementation of future CIRO or securities-law amendments.

The 2025 decisions reinforce that a well-supported application should address both the applicant’s commercial circumstances and the broader regulatory rationale for granting relief.

Looking Ahead

CIRO’s annual exemption summaries are useful indicators of where Dealer Members and Approved Persons continue to encounter friction under the evolving Canadian self-regulatory framework. They also highlight the importance of monitoring exemptive orders and related guidance, since relief granted to one firm may identify broader regulatory issues that could ultimately be addressed through rule amendments or industry-wide guidance.

Market participants should therefore treat the 2025 exemptions not only as individual decisions, but also as evidence of CIRO’s developing approach to proportionality, technological innovation and the integration of investment dealer and mutual fund dealer regulation.

For information on how to apply for an exemption from IDPC or MFD Rules, see GN-1300-21-001 Exemption applications relating to CIRO Rules.

For information on how to apply for an exemption from UMIR, see UMIR 11.1 and the related guidance set out in CIRO Rules Bulletin GN-URPart11-26-0001 Obtaining a Trading Exemption or Rule Interpretation.

Please reach out to Sean Sadler, Daanish Pasricha, Sonia Struthers or another member of our Securities Regulation & Investment Products group if you have any questions or require assistance in seeking exemptive relief from CIRO requirements.