Improving SEDAR+ functions to drive regulatory efficiency 

Submission – CSA Consultation – Amendments to Multilateral Instrument 13-102 system fees

Recipients

• Canadian Securities Administrators (CSA) 

Industry segments this resource supports

• Assets management

Summary

We submitted comments to the CSA regarding proposed amendments to multilateral instrument 13‑102, which would increase system fees for SEDAR+ and the national registration database. While we do not oppose the fee increases, we recommend several improvements to ensure SEDAR+ functions effectively, supports industry needs, and avoids unnecessary regulatory burden. The submission emphasizes the importance of system reliability, user experience, and thoughtful implementation of fee changes. 

Why this matters: Changes to SEDAR+ system fees directly affect the cost and efficiency of regulatory filings for industry participants and, ultimately, the quality of information available to investors. 

Key takeaways

• We acknowledge that the CSA’s proposed fee increases are based on cost recovery and does not oppose them. 
• We note that many major SEDAR+ challenges have been addressed but stresses the need to resolve remaining issues quickly and transparently. 
• We recommend publishing a firm timeline to fix outstanding system functionality concerns, including search performance and slow processing. 
• We propose establishing a committee with industry IT experts to help guide future SEDAR+ development and ensure appropriate transition periods. 
• We encourage the CSA to use SEDAR+ as a tool to reduce regulatory burden, such as by serving as a central repository for mandatory disclosure documents in an access‑based disclosure model. 
• We recommend amortizing the fee increase evenly over five years rather than imposing a large 60% increase in 2025. 

We advise that future fee increases should be gradual and implemented only when necessary.