Industry warns higher costs could hurt investors and weaken Quebec’s competitive position
Canada’s investment fund industry is stepping up its opposition to proposed fee increases in Quebec, calling on the province’s finance ministry to reject the changes and rethink how regulatory costs are set.
The Securities and Investment Management Association (SIMA) said the Ministère des Finances du Québec should abandon planned hikes to Autorité des marchés financiers (AMF) fees tied to investment funds, arguing the proposals lack sufficient justification and risk placing added strain on investors and firms.
In a formal submission, the industry group said it does not support the increases, citing limited transparency around how the new fees were determined and questioning their necessity given the AMF already levies the highest fund-related regulatory charges in Canada.
“Given a lack of substantiation and clarity about the proposed fee increases for investment funds, we do not support them,” SIMA said. “The AMF already charges the highest regulatory fees on investment funds in Canada. What then justifies additional fees, which will result in burden on investors’ savings and the industry’s ability to compete and innovate in Quebec?”
The latest push builds on earlier feedback submitted to the regulator and broadens the focus to the province’s overall approach to fee-setting. SIMA is urging policymakers to adopt a more structured system that improves transparency and allows firms to better plan for future costs.
“Quebec’s investment industry serves millions of investors across the province, and higher fees should not come at the expense of competitiveness or investor outcomes,” said Marie Brault, Chair of the Board of Governors, SIMA Regional Council in Quebec.
“Regulatory fees should be set within a multi-year framework with accurate cost forecasting so firms can plan, invest, and innovate with confidence,” said Andy Mitchell, President and CEO, SIMA. “Quebec has an opportunity to continue demonstrating leadership by anchoring fee-setting in three clear principles: transparency, predictability, and cost discipline.”
The proposed changes include a significant increase in filing fees for fund disclosure documents, with costs rising from $1,243 to $1,800—an increase of about 45%.
SIMA said the consultation process did not adequately explain how such increases relate to regulatory costs or investor outcomes, adding that key rationale was not clearly presented during formal consultations.
“The AMF’s consultation provided little explanation on the proposed fee increases, including how they relate to the AMF’s costs or investor outcomes,” the association said.
Beyond transparency concerns, the group warned that higher regulatory costs could ultimately be passed on to investors, potentially eroding years of progress made by the industry in lowering fees.
“Regulatory fees are built into the cost of investment funds and may ultimately be borne by investors,” SIMA said.
The association also pointed to the AMF’s accumulated surplus, arguing that those funds should be used before imposing additional charges.
“The AMF has also accumulated a significant budget surplus, which should be meaningfully deployed before fee increases are considered.”
More broadly, SIMA cautioned that rising regulatory costs could deter new entrants, limit innovation, and weaken Quebec-based asset managers’ ability to compete. The province already accounts for a relatively small share of Canada’s mutual fund and ETF assets, a gap that could widen if operating costs increase further.
The group also highlighted what it described as a growing “stacking” effect, where multiple regulatory bodies introduce fee increases independently, creating a cumulative burden that is difficult for firms to anticipate.
To address these challenges, SIMA is calling for a more coordinated and predictable system, including multi-year fee frameworks, clearer disclosure of cost drivers, and prioritization of surplus funds to improve regulatory efficiency.
“We believe it is essential for the Ministry to lead efforts toward greater transparency, predictability, and cost discipline in regulatory fees,” the association said.
