SIMA advocates for fair fees in response to CIRO proposal
November 7, 2025 (Toronto) – The Securities and Investment Management Association (SIMA) disagrees in principle with the Canadian Investment Regulatory Organization’s (CIRO) proposed new increase in fees for approved persons (AP) citing the significant impact on dealers’ budgetary processes and concerns about fee duplication and transparency.
SIMA does not, however, oppose the proposed fee amendment because it understands that CIRO cannot operate with a deficit. SIMA calls for collaboration between CIRO, the Canadian Securities Administrators (CSA), and industry stakeholders to establish a fair and predictable fee structure.
In its submission to CIRO today, SIMA says the proposed amendment, which would raise the AP annual fee from $250 to $300, is an unwelcome surprise, especially considering that it comes so soon after CIRO’s integrated fee model was implemented earlier this year. In addition, the fee hike was announced at a time when most of the industry have already planned their 2026 budgets.
“While we understand that CIRO needs to operate on a cost-recovery basis, this unexpected fee increase places undue financial burden on dealers, affecting their ability to serve clients effectively,” said Andy Mitchell, President and CEO, SIMA. “We urge CIRO and the CSA to work with the industry to create a transparent, fair, and sustainable fee model that supports market efficiency and protects investor access to advice.”
SIMA also points out that the consultation period of 30 days was too short, limiting stakeholders’ ability to respond effectively. It also criticized the lack of coordination between CIRO and CSA fee structures, warning that overlapping fees potentially reduce market access and discourage innovation. The association praised the Autorité des marchés financiers (AMF) for its proactive approach in adjusting regulatory fees to avoid duplication.
SIMA recommends procedural improvements, such as eliminating redundant registration steps when approved persons move between mutual fund dealers and investment dealers and establishing clear service standards for registration.
About SIMA
The Securities and Investment Management Association empowers Canada’s investment industry. The association is the leading voice for the securities and investment management industry, which oversees approximately $4 trillion in assets for over 20 million investors and the Canadian capital markets. Our members—including investment fund managers, investment and mutual fund dealers, capital markets participants, and professional service providers—are committed to creating a resilient, innovative investment sector that fuels long-term economic growth and creates opportunities for all Canadians.
For more information
Kia Rassekh
Director of Policy and Regional Director, Quebec
krassekh@sima-amvi.ca
514-985-7025
