CIRO’s New Proficiency Model Could Breach FSRA’s Title Protection Standards
John Waldron, Founder of Learnedly,
October 29, 2025
In Ontario, under FSRA’s title protection framework, CIRO is an approved credentialing body (CB), which permits its registrants to use the “financial advisor” title. But this could change in 2026 when CIRO moves to a new, assessment-centric proficiency model.
Under the proficiency model, CIRO will administer the licensing exams, but leave the curriculum to the open market of course providers, rather than developing its own training programs.
CIRO has also said it will not review or approve curricula developed by educators – leaving quality control to “market forces”. If CIRO falls short of FSRA’s requirements, this is why.
Among other requirements, FSRA requires an approved credentialing body to:
Submit its policies and procedures on its approach for regularly reviewing its education curriculum
Regularly review its educational curriculum to ensure that it is up to date
The intention behind FSRA’s requirements is to maintain consistent standards across credentialing bodies and those who are permitted to use the “financial advisor” title.
As of the end of October, FSRA has yet to issue its position on CIRO’s CB status.
What are the implications?
If FSRA determines that CIRO’s new approach doesn’t meet its standards, it’s unlikely to have an impact on existing registrants. However, new registrants licensed through CIRO’s new proficiency model may not be granted the right to use the “financial advisor” title without obtaining an approved credential, above and beyond their licensing status.
The integrity of the “financial advisor” title depends on more than just passing an exam — it depends on education that meets regulatory standards and public expectations. FSRA and CIRO need to resolve this potential gap before 2026, or risk undermining both systems.
Call to action
Industry leaders, education providers, and registrants should speak up now. Ask FSRA and CIRO how they plan to maintain consistent, credible standards for financial professionals.
Without oversight and accountability, proficiency becomes a promise without proof. It erodes trust in the industry and credibility among its professionals.