Guidance on CIRO Proficiency Model
The Canadian Investment Regulatory Organization (CIRO) will implement a new assessment-centric proficiency model for Approved Persons of investment dealers effective January 1, 2026, replacing the current course-centric approach with a framework that includes competency-based exams, mandatory conduct training, and specific exemptions for currently approved individuals.
Assessment-Centric Proficiency Approach
The new model shifts away from mandatory prerequisite courses to a system where individuals can prepare for proficiency assessments in whatever manner they choose. Exams will be based on published competency profiles specific to each Approved Person category, allowing for more flexible preparation paths. This approach enables candidates to leverage their existing knowledge and experience rather than following a rigid course structure.
Under this framework, CIRO will take a more active role in designing and delivering proficiency programs, ensuring standards remain current, relevant, and responsive to industry needs. The goal is to create a more adaptable system that focuses on demonstrated competencies rather than course completion, while maintaining high standards for individuals working at investment dealers.
Mandatory Training Requirements
All individuals approved after January 1, 2026, must complete mandatory conduct training within 30 days of their approval date. This requirement extends to existing Approved Persons as well, who have until December 31, 2026, to fulfill this obligation while maintaining their current roles.
The training component represents a significant shift in CIRO's approach to professional standards, complementing the assessment-focused model with ongoing educational requirements. This mandatory conduct training ensures all investment professionals maintain current knowledge of ethical standards and regulatory expectations, regardless of when they received their initial approval.
Transition and Exemption Provisions
Individuals approved before January 1, 2026, who remain in the same role are generally exempt from new proficiency requirements, though they must complete the mandatory conduct training by December 31, 2026. Several specific exemptions have been established to facilitate a smooth transition:
Professionals with at least two years of experience in the same Approved Person category within the last three years may be exempted from the Canadian Investment Regulatory Exam (CIRE).
Those currently approved for options or futures trading will be grandfathered into their existing categories without needing new exams, unless they wish to deal in all derivatives or experience a break in approval exceeding 180 days.
FINRA registrants with similar capacities within the past three years who have completed relevant exams (like SIE and Series 7) are exempt from the CIRE.
Individuals enrolled in Canadian Securities Institute courses before January 1, 2026, have until December 31, 2026, to complete exams and until January 1, 2027, to submit approval applications.
These provisions recognize existing credentials while ensuring a gradual transition to the new standards without disrupting the industry or imposing undue burdens on current professionals.