SIMA responds to CSA consultation on ETF regulation
TORONTO, October 31, 2025 – The Securities and Investment Management Association (SIMA) has responded to the Canadian Securities Administrators’ (CSA) consultation on enhancing exchange-traded fund (ETF) regulation. SIMA’s submission reflects input from ETF manager and capital markets members, and is informed by the association’s research in addition to the Ontario Securities Commission’s (OSC) empirical analysis of Canadian ETF liquidity and the effectiveness of the arbitrage mechanism.
While SIMA supports several of the CSA’s proposals, the association only supports proposed measures that it believes contributes to improved investor understanding, decision making, or protections. SIMA advocates for principles-based regulation that promotes competitiveness and innovation, rather than prescriptive requirements that may not address identified market issues. The submission emphasizes that some proposed amendments could increase costs that may be borne by investors and recommends that reforms be carefully targeted to address concerns supported by empirical evidence.
“The OSC’s empirical review found that the current ETF framework is functioning effectively,” said Andy Mitchell, President and CEO of SIMA. “The CSA’s consultation raises important questions about the necessity of certain proposed changes. We believe reforms should be supported by clear evidence of demonstrable issues and carefully balanced to ensure they strengthen investor protection without undermining the success, innovation, and competitiveness of the Canadian ETF marketplace.”
SIMA’s submission emphasizes the value of maintaining flexibility for ETF managers that have diverse business models in addition to the need for cost-benefit analysis when considering new regulatory requirements. The association supports applying the CSA’s behavioural research and investor testing approach to evaluate proposed ETF disclosure changes.
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
Christine Harminc
Director, Communications and Public Affairs
charminc@sima-amvi.ca
416-309-2313
