Business Law and Corporate Law

On June 25, 2026, the Canadian Securities Administrators (the CSA) published [PDF] final amendments to National Instrument 51-102 – Continuous Disclosure Obligations and National Instrument 54-101 – Communication with Beneficial Owners of Securities of a Reporting Issuer and their related companion policies to implement an optional alternative model for the delivery of certain continuous disclosure documents by non-investment fund reporting issuers.

Tax structuring is typically the starting point – for the company, the founders, and the investor, particularly in cross-border transactions. Non-Canadian investors should get tax advice both in Canada and in their home jurisdiction.

For growing companies, issuing shares for services can preserve scarce cash and align incentives. Reverse vesting pushes that logic further: it allows a company to grant shares upfront while retaining a mechanism to claw them back if expectations are not met.