ARTICLE
11 July 2025

Next Wave Of CIRO Proficiency Requirements

BL
Borden Ladner Gervais LLP

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BLG is a leading, national, full-service Canadian law firm focusing on business law, commercial litigation, and intellectual property solutions for our clients. BLG is one of the country’s largest law firms with more than 750 lawyers, intellectual property agents and other professionals in five cities across Canada.
The Canadian Investment Regulatory Organization (CIRO) is shifting from a course centric proficiency model with exams tied to courses, to an assessment centric model with mandatory continuous education and training.
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The Canadian Investment Regulatory Organization (CIRO) is shifting from a course centric proficiency model with exams tied to courses, to an assessment centric model with mandatory continuous education and training. On April 17, 2025, it was announced that the members of the CSA have approved amendments to Rules 2500 to 2800 of CIRO's IDPC Rules to establish this model, to be effective as of January 1, 2026.

The amendments repeal the current mandated course-based provisions and replace them with new exam-based provisions. New relevant baseline education and experience provisions for some Approved Person categories have been added, along with new provisions related to conduct training which will be provided by CIRO. Current training provisions will be repealed and replaced with others to better align with CIRO's proficiency principle and competency profiles, including new mandated annual continuing education training specifically prescribed by CIRO. New transitional rules and exemptions have been added, which govern the coming into force of the new requirements. CIRO has also adopted a single derivatives product approach, for consistency with the Derivatives Rule Modernization Project, Stage 1.

In addition, CIRO released Guidance on the new CIRO Proficiency Model for Approved Persons of Investment Dealers – Exemptions, Recognition, Transition and Validity Provisions. The Guidance will help dealer members and Approved Persons prepare for the implementation of the new proficiency model. On the same date, CIRO published Guidance on Dealer Member training for Registered Representatives and Investment Representatives. Under the new proficiency model dealers must provide training to registered representatives and investment representatives within 90 days of approval. The Guidance helps inform dealers of the training program requirements that replace the current pre-registration dealer training requirements. Further guidance will be published relating to the relevant education and experience requirements.

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