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In advance of the new proficiency model set to come into effect on January 1, the Canadian Investment Regulatory Organization (CIRO) has been busy this last quarter releasing guidance aimed at helping dealers and their approved individuals understand the new regime.
As examples, on September 26, 2025, CIRO released Guidance on Relevant Education and Experience Requirements (Education Guidance) which relates to compliance with the proficiency principles for minimum education and experience requirements, dealer considerations regarding relevant education and experience requirements, and reporting on the National Registration Database (NRD).
The Education Guidance describes factors for dealers to help assess the relevancy of an individual's education or experience before submitting an application to CIRO for approval. Considerations include the applicable CIRO approval category, including client and product types, the dealer's business model as it applies to the approved role, and the activities and responsibilities of the Approved Person.
That same day, CIRO also released guidance concerning CIRO Proficiency Exemption Requests (Exemption Guidance) providing a general overview of the CIRO proficiency exemption request process for investment dealers and Approved Persons, as well the information required when requesting an exemption from CIRO exams. The Exemption Guidance notes that the onus is on the dealer and the applicant to provide the information for CIRO to determine if the alternative proficiency (such as an alternative educational course, training or experience) is acceptable and (at a minimum) equivalent to the applicable prescribed proficiency requirement.
The Exemption Guidance specifies that staff will not support an exemption based on a course or materials intended as preparatory for passing a CIRO exam. It also notes that staff would not support an exemption application from the relevance requirement with respect to an applicant's education or experience. If a request is made on the basis of equivalent education or experience, a comparative analysis must be provided in order to support the request, and such information can be presented in the form of tables, charts or descriptive paragraphs that clearly demonstrate equivalency.
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