CIRO’s 2027 Annual Priorities

This bulletin presents the Annual Priorities of the Canadian Investment Regulatory Organization (CIRO) for our 2027 fiscal year (April 1, 2026 to March 31, 2027). Annual Priorities provide our members, investors and other industry stakeholders with a preview of upcoming CIRO initiatives, ensuring transparency regarding CIRO's regulatory focus for the year ahead. By publishing these priorities our aim is to build accountability and transparency about our work with the aim of giving shareholders ample opportunity to engage meaningfully with CIRO.

This year will be the final year of CIRO's current 2025-2027 Strategic Plan and these priorities represent our final effort towards achieving our strategic objectives.

The priorities outlined in this Notice:

• Reflect CIRO's continued delivery against its Strategic Plan;
• Build on the successful completion of all Fiscal 2026 priorities; and
• Balance near-term regulatory initiatives with preparation for the next strategic planning cycle.

Update on Fiscal 2026 Annual Priorities and 2025-2027 Strategic Plan

CIRO successfully delivered on all Annual Priorities for Fiscal 2026.

The 2025-2027 Strategic Plan was the product of significant collaboration with members and other stakeholders on CIRO's role as a regulator. Through that collaboration, CIRO was able to identify and target areas for enhancement that would address the needs of Canadian investors and the industry of the future.

CIRO's Strategic Plan includes six strategic objectives:

• Integration
• Regulatory Evolution
• Access to Advice
• Investor Research, Education and Protection
• Registration and Proficiency; and
• Market Regulation

All six objectives are reflected in the Annual Priorities for the upcoming fiscal year. Integration has been treated separately to reflect the heightened level of importance placed on this strategic objective at this time.

Fiscal 2027 Annual Priorities

Consistent with prior years, the Annual Priorities were developed with the following principles in mind:

• Ability to deliver on the strategic objectives set out in our three-year Strategic Plan
• Consideration for changes that may require us to pivot and respond as the industry changes, and
• Impacts to members, investors and other stakeholders, including the time and cost that may be involved for them to respond to CIRO initiatives.

Integration Priorities

CIRO was formed through the amalgamation of the Investment Industry Regulatory Organization of Canada and the Mutual Fund Dealers' Association of Canada.

Integration has already delivered efficiencies and continues to create opportunities to generate additional value for investors, members, and other stakeholders. As CIRO enters the final year of its Strategic Plan, the organization will focus on completing several key initiatives designed to harmonize regulatory frameworks and reduce unnecessary complexity.

In Fiscal 2027, CIRO will:

• Publish a final harmonized rulebook consolidating investment dealer and mutual fund dealer rules.
• Consult on and finalize proposed rule amendments relating to the adoption of an incorporated advisor compensation option for submission to the Canadian Securities Administrators (CSA) for review and approval.
• Propose Phase 2 rule amendments to complete the harmonization of the Continuing Education (CE) regime by aligning requirements related to credits, cycles, exemptions, proration, reporting and scope.
• Consider the retirement of the dual registration regulatory construct by finalizing rule amendments for CSA review and approval that would repeal the proficiency upgrade requirement for mutual fund-only advisors and codify the exemptive relief conditions under which existing dual-registered firms operate.

Priorities to Advance Other Strategic Objectives

In addition to integration priorities, we will continue to advance initiatives aligned with the remaining strategic objectives in our Strategic Plan.

Investor Research, Education and Protection

Protecting investors and strengthening confidence in Canadian capital markets is central to CIRO's mandate. To do that effectively, we need to review complaint handling practices, develop deeper understanding of Canadian investors, build a robust pan-Canadian approach to investor education and stay apprised of emerging trends impacting the industry.

In Fiscal 2027, CIRO will:

• Conduct a review of complaint handling resolution timelines.
• Work with the CSA to enhance the fraudulent website disruption initiative launched in Fiscal 2026 by refining and expanding its capabilities.
• Leverage stakeholder engagement and research conducted in Fiscal 2026 to identify opportunities to strengthen investor protection and streamline disclosure requirements.
• Complete and publish research examining whether behavioural interventions ("speed bumps") can help DIY investors pause, reflect, or learn before engaging in higher-risk investment strategies.
• Improve the account transfer process for investors by:
  • Publishing revised proposed rule amendments for further public comment; and
  • Publishing a second phase of CIRO's white paper providing an update on the development of a potential technology solution.
• Implement the concept of "Reasonable Safeguards", providing structured and practical compliance guidance through CIRO bulletins to reduce regulatory uncertainty, promote consistent supervisory outcomes, and support firms in demonstrating good-faith compliance with Client-Focused Reforms obligations.

Regulatory Evolution

The investment industry continues to evolve rapidly. CIRO's vision is to be an agile regulator that supports responsible innovation while delivering efficient, effective and cost-conscious regulatory oversight, and to do so in ways that reflect investor, dealer and marketplace needs.

In Fiscal 2027, CIRO will:

• Build on the operational efficiency program established in Fiscal 2026 by implementing further improvements through the use of technology and automation within CIRO's Policy, Compliance and Registration functions.
• Enable member firms to test innovative ideas through InnovateSafe, CIRO's regulatory sandbox.
• Strengthen cyber resilience across the industry by:
  • Developing and consulting on a data collection and management framework for CIRO, its Dealer and Marketplace Member firms, and Registered Persons; and
  • Conducting a cybersecurity tabletop exercise for small and medium-sized member firms.

Access to Advice

Expanding access to advice that meets the evolving needs of Canadian investors remains a key priority for CIRO.

In Fiscal 2027, CIRO will focus on reviewing the regulatory framework applicable to tailored online advice to support broader access to regulated advice. Specifically, CIRO will:

• Assess stakeholder feedback on the current regulatory framework governing tailored online advice and develop recommendations for regulatory changes where appropriate.

Registration and Proficiency

Our strategic objective is to modernize the registration regime and proficiency standards of registrants. In the year ahead we will:

• Operationalize delegated responsibilities for mutual fund and investment dealer registration functions across all Canadian jurisdictions.

Market Regulation

CIRO is committed to providing effective and appropriate market regulation that fosters fair and efficient capital markets and further builds confidence in Canada's capital markets. In the year ahead, we will:

• Publish the first annual report on Market Regulation operations providing greater transparency into CIRO's market oversight activities.
• Review the Universal Market Integrity Rules (UMIR) to identify requirements that could be modified to better support small dealers and junior issuers.

Quarterly Policy Initiatives Update

CIRO publishes a Quarterly Policy Initiatives Update to keep members, stakeholders, advocacy groups and the industry apprised of the timing of our policies and proposals. For each initiative, we provide our estimate of when stakeholders may be required or invited to take appropriate action. We publish this report so that all interested parties can plan for and / or respond to initiatives on a timely and efficient basis.