Canadian Securities Administrators Modernize Investment Fund Continuous Disclosure: Final Amendments Released

The Canadian Securities Administrators (CSA) have finalized a package of amendments to modernize the continuous disclosure regime for investment funds. The changes streamline related party transaction reporting, align certain financial statement disclosures with International Financial Reporting Standards (IFRS) by removing low‑utility class or series distinctions and make targeted updates to simplified prospectus disclosure. The CSA will continue separately with Workstream One to replace the management report of fund performance (MRFP) with a new fund report and to introduce fund expense ratio (FER) references in fund facts or exchange traded funds (ETF) facts.

The final amendments will come into force on April 22, 2026, with transition periods to January 1, 2027, for key items, as outlined below.

What has changed

Workstream Two – related party transactions (RPT)

The CSA are replacing overlapping statutory RPT reporting with a standardized framework centered on National Instrument 81-107 Independent Review Committee for Investment Funds (NI 81‑107):

• Each financial year managers are required to prepare a "Manager's Report on Related Party Transactions" which must be added to the independent review committee (IRC) annual report to security holders. This appendix must list RPT reports filed on SEDAR+ during the year and provide a brief description of other transactions involving an entity related to the manager that were not otherwise subject to a filed report.
• A new Form 81‑107A "Conflict Reporting Form for Related Issuer Purchases" standardizes disclosure for reports under NI 81‑107. The form requires concise, plain‑language tabular disclosure of key particulars (issuer, security, quantity, price, settlement amount, compensation to any related person or company, whether a related dealer was used and whether it occurred in the primary or secondary market).
• Duplicative "investment fund conflict of interest reporting requirements" in securities legislation do not apply where a fund files a Form 81‑107A report.

Notable changes that arose from consultation include removal of the preparation date field in Form 81‑107A, removal of a requirement to list sources of independent quotes or pricing for debt securities, and clarification that disclosure of compensation covers fees, commissions or other forms of consideration. Where a related dealer is used, the form requires this to be stated and the related dealer named.

Workstream Three – financial statements

To reduce complexity and align with IFRS, the CSA are eliminating certain class or series‑level disclosures in National Instrument 81-106 Investment Fund Continuous Disclosure (NI 81‑106):

• Removal of class or series granularity from specified items in the statement of comprehensive income and statement of changes in financial position, and deletion of certain note‑level disclosures that provided limited utility to investors.
• Consequential simplifications to presentation line items in interim or annual financial reports.

The CSA considered IFRS 18 and set the transition to align with its January 1, 2027, application.

Who is affected

• Reporting issuer investment funds (including mutual funds and ETFs).
• Investment fund managers, given new annual RPT summarization and use of Form 81‑107A for specified purchases.
• IRCs, which will append the manager's RPT report to their annual report to security holders.

Practical implications and action points

• Map current RPT processes against NI 81‑107.
• Update disclosure controls and procedures.
• Review simplified prospectus format.
• Engage with service providers.
• Align SEDAR+ filing practices with the new Form 81‑107A format.

What's next

The CSA will publish separately on Workstream One, including the replacement of MRFPs with a streamlined annual and interim fund report and the inclusion of FER in fund facts or ETF facts. This will involve further content, format and systems changes for NI 81‑106 reporting.

Key takeaways

• The amendments deliver tangible burden reduction by eliminating duplicative and low‑utility disclosures while preserving investor protection through standardized, plain‑language RPT reporting.
• Most operational change centres on building the new annual manager's RPT appendix to the IRC report and adopting Form 81‑107A, with a roadmap to January 1, 2027, for transition.
• Separately, further changes are anticipated once the CSA finalize Workstream One on fund reports and FER.