CSA Coordinated Blanket Order 33-930 - Exemptions From Certain Personal Information Requirements Under NI 33-109

On April 30, 2026, the Canadian Securities Administrators (CSA) issued Coordinated Blanket Order 33-930 Exemptions from Requirements to Submit Certain Personal Information Under National Instrument 33-109 Registration Information (the Coordinated Blanket Order), providing harmonized exemptions across all CSA jurisdictions from the requirement for individuals to submit or update certain personal information under National Instrument 33-109 Registration Information (NI 33-109). The Coordinated Blanket Order comes into effect on May 1, 2026.

Background

Under the registration regime established by NI 33-109, firms required to be registered as dealers, advisers and investment fund managers and certain individuals acting on their behalf must submit specified personal information when applying for registration (including reinstatement) or seeking review as a permitted individual. The information collected is used by the CSA to assess a filer's fitness for registration or permitted individual status.

Among the information currently required to be submitted in Form 33-109F4 Registration of Individuals and Review of Permitted Individuals is: (i) eye colour, hair colour, height and weight; and (ii) citizenship information (country of citizenship and passport information for individuals who are citizens of countries other than Canada).

Following a review, the CSA has determined that eye colour, hair colour, height and weight information is not required to identify individuals submitting information under NI 33-109 or otherwise to determine their fitness for registration or permitted individual status. While citizenship information is sometimes used to confirm an individual's identity as part of the registration process, the CSA has concluded that, when needed, such information can be collected outside of the requirements in the Instrument.

Scope of relief

The Coordinated Blanket Order provides relief from the obligation to submit eye colour, hair colour, height, weight and citizenship information by:

• exempting individuals from the requirements to provide this information in Form 33-109F4 when applying for registration (including reinstatement) or seeking review as a permitted individual; and
• exempting individuals from requirements to notify CSA members of changes to this information previously submitted in respect of an individual's Form 33-109F4.

The Coordinated Blanket Order comes into effect on May 1, 2026. In all jurisdictions except Ontario, the relief will expire on the date on which amendments to NI 33-109 come into force that address substantially the same subject matter as the Coordinated Blanket Order (the Amendment Date). In Ontario, the Coordinated Blanket Order will expire on the earlier of: (i) November 1, 2027, or such later date to which it is extended; and (ii) the Amendment Date. The difference in Ontario reflects the statutory 18-month term limit applicable to blanket orders issued by the Ontario Securities Commission.

Practical implications for registrants

This is a welcome, though modest, burden-reduction measure for registered firms and their individual registrants. In practical terms:

• Individuals completing Form 33-109F4, whether for initial registration, reinstatement or permitted individual review, will no longer be required to disclose eye colour, hair colour, height, weight, or citizenship and passport information.
• Firms will no longer need to monitor or report changes to these data fields for their registered individuals or permitted individuals.
• No action is required by firms or individuals in respect of personal information previously submitted. The obligation to update that information going forward is simply removed.

The CSA has indicated that it plans to remove these requirements permanently when NI 33-109 is next formally amended, making the Coordinated Blanket Order an interim measure pending completion of that rule-making process.

Broader context

The Coordinated Blanket Order is part of a broader CSA initiative to reduce regulatory burden on market participants without compromising investor protection. Over the past year, the CSA has issued a number of coordinated blanket orders across various areas of securities regulation including prospectus and disclosure streamlining, the listed issuer financing exemption, semi-annual reporting for venture issuers, and exempt market dealer participation in selling groups, each reflecting a commitment to a more proportionate and responsive regulatory framework.

Local variation

Although the outcome is the same in all CSA jurisdictions, the language of the Coordinated Blanket Order issued by each province or territory may not be identical, as each jurisdiction's blanket order must be consistent with the authority provided under its local securities legislation. Firms operating in multiple jurisdictions should confirm the specific terms of the local order applicable in each jurisdiction in which they are registered.

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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. Specific Questions relating to this article should be addressed directly to the author.

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.