The Canadian Investment Regulatory Organization (CIRO) launched a consultation on its proposed consolidated rules regarding dual registration on February 12, 2026. This regulatory concept has existed since the merger of the Mutual Fund Dealers Association of Canada (MFDA) and the Investment Industry Regulatory Organization of Canada (IIROC) into the New Self-Regulatory Organization on January 1, 2023, which was later renamed CIRO.

Dual registration allows a dealer to register for both investments and mutual funds without requiring advisors exclusively active in mutual funds to bring their qualifications up to the level of those of investment advisors.

On the same day, CIRO launched a consultation on its proposed consolidation of the rules governing the two categories of dealers. The exercise aims to consolidate the two sets of rules inherited from the MFDA and the IIROC. This consultation marks the final stage of rule consolidation, as it seeks feedback on all five phases of this massive regulatory undertaking.

The industry must respond to these two consultations by June 12, 2026. CIRO has posted the two draft rules for consultation on its website.

Dual registration eliminated

In the proposed amendment regarding dual registration, CIRO proposes simplifying advisor registration requirements. It also aims to create a single framework for mutual fund and investment dealer members.

The self-regulatory organization believes that dual registration is no longer necessary since its consolidated rules will harmonize the two sets of rules. Its proposed amendments abolish this requirement as follows:

  • repealing the proficiency upgrade requirement for mutual fund-only advisors who work at an Investment Dealer Member, and
  • codifying exemptive relief conditions under which existing dual-registered firms operate.

 We believe repealing the proficiency upgrade requirement will improve advisor mobility across CIRO-regulated firms and harmonize proficiency across Dealer Member types.
– CIRO

Once the regulations are amended, an investment dealer will be able to operate a mutual fund division without registering as a mutual fund dealer. CIRO clarifies that the Approved Person categories of ‘Investment Representative dealing in mutual funds only,’ and ‘Registered Representative dealing in mutual funds only’ will remain.

However, these categories will no longer be subject to the proficiency upgrade requirement, the CIRO states. “We believe repealing the proficiency upgrade requirement will improve advisor mobility across CIRO-regulated firms and harmonize proficiency across Dealer Member types,” the self-regulatory body maintains.

A project that will soon be three years old

Regarding the consolidated rules for mutual fund dealers and investment dealers, the consultation of February 12, 2026, covers the entire project. Initially called the New Self-Regulatory Organization of Canada (New SRO), CIRO began operations under its current name on June 1, 2023. It published an update on June 30 of the same year to outline its rule consolidation project.

In total, the five phases of the project generated 77 comment letters. Each phase was the subject of a separate consultation.

  • Phase 1 aimed to establish the rule structure for mutual fund dealers and investment dealers.
  • Phase 2 focused on adopting provisions to be retained from the rules governing mutual funds and investments.
  • Phase 3 addressed business and member business authorization, clearing, settlement of transactions, delivery standards, and inspection, investigation, and enforcement rules.
  • At the end of Phase 4, rules were adopted regarding the authorization and qualifications of Approved Persons, the management of significant risk categories, and rules on business conduct and client accounts.
  • Phase 5 aimed to adopt common requirements for the rules governing mutual fund dealers and brokers. These are rules whose evaluation reveals differences deemed significant that could have a significant impact on stakeholders, explains the CIRO.

Of all the project phases, Phase 5 received the most comments, with 22 letters. Launched on March 27, 2025, it ended on June 25, 2025.

A final round of comments

The consultation on February 12, 2026, is a call for further comments on its proposed consolidated rules across all five phases. These rules will now be called the Canadian Investment Regulatory Organization (CIRO) Rules, rather than the CIRO Dealer and Consolidated (DC) Rules.

The self-regulatory organization intends to follow up on the comments received and make significant changes to the requirements of the proposed rules published in previous phases, according to the summary page of its consultation.

The objectives of the Proposed CIRO Rules are numerous. It aims to achieve the following results, summarized below:

  • minimize regulatory arbitrage between Investment Dealer Members and Mutual Fund Dealer Members
  • ensure like dealer activities will be regulated in a like manner
  • adopt less prescriptive, more principles-based rule requirements.
  •  improve the clarity of the rules. CIRO intends to achieve this by modifying their formatting and grammar.

No going back

There will be no going back on harmonization, judging by CIRO’s findings from previous consultations. The SRO says it has determined that rules consolidation enjoys broad support from the various stakeholders.

On the one hand, the SRO acknowledges that rules consolidation could place an additional burden on dealers. The requirement to have a chief financial officer is, according to it, one example.

On the other hand, CIRO praises certain merits of the project for members, including the requirement to be based on principles. The SRO believes that such requirements give members more flexibility in fulfilling their regulatory obligations.

CIRO sees only positive impacts for investors. For example, the rules impose measures that reduce the risk of a dealer member's insolvency.

It also argues that the requirements will be more comprehensive and consistent, particularly with regard to business conduct, internal investigations, and complaint handling. The regulator also mentions the imposition of more consistent and uniform practices regarding client disclosure.