The Canadian Investment Regulatory Organization (CIRO) has proposed rule amendments that will shorten the standard response times for investor complaints, from 90 days to 60 days, in line with relatively new standards in force in Quebec.

Currently they say timelines for handling consumer complaints differ across the country. “Dealers subject to the Autorité des marchés financiers (AMF) requirements in Quebec generally have 60 days to provide a final response, while dealers in other provinces generally have 90 days under CIRO rules,” CIRO stated at the opening of the comment period on the new, nationally applicable regulations.

“The proposed amendments will harmonize CIRO’s requirements with Quebec’s current complaint-handling framework, establishing a consistent 60-day standard timeline nationwide. An additional 30 days will be available for particularly complex complaints or delays beyond a dealer member’s control.”

In Quebec, the AMF’s complaint handling regulation came into effect on July 1, 2025. CIRO says the inconsistency between the different requirements raised questions as to whether CIRO’s existing 90-day response period remained appropriate.

“Aligning CIRO’s requirements with the 60-day standard under Quebec’s framework will promote equal and more consistent treatment across Canada,” CIRO’s representatives write in an email exchange with the Insurance Portal. “The introduction of Quebec’s 60-day complaint handling standard prompted CIRO to consider the fairness and consistency concerns created by different timelines across Canada.”

In this email exchange, CIRO’s representative continues, saying the 90-day timeline has its roots in the rules created under CIRO’s predecessor organizations, and has long been the industry standard. They also say the rule is consistent with the Canadian Securities Administrators’ (CSA) National Instrument 31-103.

In the rule proposal drafted for comment, the regulator notes that the national instrument governing portfolio managers and exempt market dealers “encourages” firms to resolve complaints within 90 days. “It does not prescribe a specific complaint response timeline,” the document states.

Investor expectations

CIRO’s representative says investor expectations have changed, noting that regulators in some jurisdictions, including Quebec, have adopted shorter timelines. Equitable, consistent and timely access to the complaint-handling process is an important part of CIRO’s investor protection mandate, the representative says. The proposed amendments would establish a clear, consistent national standard that better reflects investors’ current expectations.

In the regulator’s 2024 Investor Survey, they found that 70 per cent of those responding to the survey said the current 90-day time frame was unreasonable. Investor advocates, meanwhile, tell CIRO that long timelines erode investor trust and can worsen harm, particularly in cases involving financial misconduct.

Dealers however, in consultations with CIRO, say complex complaints are common, rather than exceptional and have consistently expressed strong support for retaining the 90-day response period, even though this would create a geographically based, two-tiered complaint handling regime.

“The feedback from Dealer Members was that 90 days provided an appropriate amount of time to conduct a thorough investigation and propose a fair and reasonable resolution,” CIRO states. “In addition, they indicated that shortening the response period would require firms to devote specialized additional resources to this function, which would require a significant transition period to hire and train staff.”

According to the summary published for comment, some proposed amendments:

  • create an obligation for dealers to provide a substantive response to a complaint, or address a service complaint within 60 days of receiving the complaint,
  • do not introduce a requirement to file service complaints with CIRO,
  • provide dealers with an additional 30-day response period where the resolution of the complaint is particularly complex, or there are circumstances beyond the dealer member’s control are causing complaint management delays.

Source: Canadian Investment Regulatory Organization (CIRO).

CIRO is expected to also provide guidance to help dealer members determine when the additional 30-day period may be appropriate: “Complaints involving disputed suitability assessments, estate or tax matters, multiple accounts, unapproved outside activities, personal financial dealings or former employees may require more time. Service or administrative matters, transaction errors, margin issues and account transfers would generally be expected to be addressed within 60 days.”

Investor advocates have also highlighted dealer’s use of non-disclosure agreements (NDAs) in resolutions with complainants – a point CIRO intends to also address in its future guidance document on the topic.

“NDAs should not pertain to matters outside of the specific complaint or issue to which the settlement applies. NDAs should also not unduly restrict disclosure to certain parties where disclosure would be customary, and in the client’s best interests, such as spouses, legal counsel, persons required to financially deal with the settlement funds, and persons qualified to provide medical, psychological, mental health, spiritual or other related support,” the proposed amendments state.

Resolution timelines improve nationally following Quebec implementation

According to the CIRO’s complaint and settlement reporting system, 69.4 per cent of complaints in Quebec are resolved within 60 days. Just 23.1 per cent of complaints in the rest of the country are handled in the same amount of time. In Quebec, since the implementation of the AMF regulation, the proportion of complaints resolved in 60 days reportedly increased from 33 per cent to over 91 per cent, according to the AMF’s data.

More, CIRO’s data shows that complaint resolution times have also decreased across the country since the Quebec regulation came into effect. “In Quebec the average time to resolve a complaint decreased to 65 days from 89 days. During the same period, the average time to resolve a complaint in jurisdictions outside Quebec decreased to 78 days from 105 days,” they write.

Implementation of the new rules will depend on the feedback given during the consultation period. The comment period regarding the proposed changes closes January 27, 2027.