A practical approach to CIRO CE harmonization
SIMA is advocating for a more practical, efficient, and harmonized continuing education framework that reduces administrative burden, improves accountability, and better reflects how investment industry participants operate.
Submission – CIRO – Proposal to harmonize CIRO continuing education programs – Phase 2 (July 15, 2026)
Recipients
- Canadian Investment Regulatory Organization (CIRO), Registration, Proficiency Department
- Ontario Securities Commission (OSC), Trading and Markets
- Alberta Securities Commission (ASC), Market Oversight
Industry segments this resource supports
- Assets management
- Wealth management
Summary
SIMA supports CIRO’s objective of harmonizing continuing education (CE) programs for mutual fund dealers and investment dealers and believes harmonization can improve efficiency and reduce regulatory burden. However, SIMA recommends several changes to ensure the framework better meets industry needs. Key recommendations include adopting CERTS as the prescribed reporting system, assigning responsibility for CE completion and reporting to Approved Persons rather than dealers, maintaining the use of CE credits rather than hours, providing clear guidance on proration, exemptions and accreditation, retaining a December 1 cycle start date, and implementing an 18 month transition period.
Why this matters: SIMA is advocating for a more practical, efficient, and harmonized continuing education framework that reduces administrative burden, improves accountability, and better reflects how investment industry participants operate.
Key takeaways
- SIMA supports the overall goal of harmonizing CE requirements across mutual fund and investment dealers.
- SIMA recommends designating CERTS as the prescribed reporting platform because it offers automated tracking, proration management, detailed reporting capabilities, and reduced administrative burden.
- SIMA believes Approved Persons should be responsible for completing and reporting CE requirements, while firms should maintain reasonable supervisory processes rather than being held accountable for individual compliance outcomes.
- The submission recommends retaining the term “credits” instead of “hours” to remain consistent with terminology used by other regulators.
- SIMA calls for greater clarity regarding proration, exemptions, accreditation, and knowledge-assessment requirements.
- SIMA recommends maintaining a two-year CE cycle beginning on December 1 rather than January 1.
- An 18 month implementation and transition period is recommended to allow firms sufficient time for system integration, training, and operational changes.
- SIMA encourages mutual recognition of CE credits with the Chambre de l’assurance, where appropriate, to help avoid duplication of requirements.
- SIMA recommends a risk-based approach for CFO continuing education requirements, proposing 10 CE credits over a two-year cycle.
