On June 26, 2025, the Autorité des marchés financiers (AMF) published a notice of consultation regarding changes to certain fees and penalties prescribed by the Securities Act (Québec) and the Derivatives Act (Québec). Because the AMF's funding model operates on a cost-recovery basis, the proposed adjustments to the fee model are intended to capture the changing realities of the financial markets in Québec.
While the proposals would result in a reduction of certain fees, they would also result in the introduction of new fees that are impactful to our clients. The AMF is seeking input from market participants on these proposals until Sept. 19, 2025.
Key changes considered
The AMF is seeking to recalibrate its fees to allocate regulatory costs more fairly and proportionately among market participants and to ensure adequate coverage of the costs associated with the emergence of new financial activities. Below is a summary of the AMF's proposed fee changes:
| Category | Description | Previous fee | New fee | Change type |
|---|---|---|---|---|
| Annual renewal fees (Investment Dealers, Mutual Fund Dealers, individuals) | Reflects delegation of certain functions to CIRO | ID: $2071 Rep: $242 MFD Rep: $219 |
ID: $518 ID Rep: $61 MFD Rep: $55 |
Decrease |
| International Dealers, Advisers, Non-Resident Fund Managers | Operating under a statutory exemption | None | $3,000 | New fee |
| Pre-filing consultations with AMF | Fee per consultation | None | $2,000 | New fee |
| Exemptive Relief Applications | Review fee | $690 | $2,000 | Increase |
| Late penalty for 45-106F1 filings | Penalty per business day late | None | $100/day up to $5,000/year | New |
| Fees & penalties under Securities Act & Derivatives Act | General update | Not specified | Updated amounts | Increase |
To the extent that these proposed fee changes will impact your business, you may wish to provide the AMF with your comments. Please reach out to your BLG trusted advisor if you would like assistance formulating your response or navigating these fee recalibrations.
Footnote
1. For context, international dealers, advisers and non-resident investment fund managers currently pay capital market participation fees in Ontario based on their revenue. International dealers and advisers also pay initial and annual fees in certain other provinces, such as Alberta, British Columbia, Manitoba, Saskatchewan, and New Brunswick. We also note that the AMF proposal is silent as to whether similar fees would apply to advisers and dealers operating under a statutory exemption from the registration requirement under National Instrument 93-101 Derivatives: Business Conduct.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
