It is voluntary - but it changes how your clients get their financial statements
Canada's securities regulators finalized a voluntary model letting public companies give investors electronic access to financial statements instead of mailing them.
The Canadian Securities Administrators published the final amendments on June 25, 2026, and they will come into force on September 22, 2026, provided all necessary ministerial approvals are obtained, according to the notice. The changes amend National Instrument 51-102 Continuous Disclosure Obligations and National Instrument 54-101 Communication with Beneficial Owners of Securities of a Reporting Issuer, along with their companion policies.
The Access Model covers annual financial statements, interim financial reports and related management's discussion and analysis - the documents the CSA calls CD documents - filed by reporting issuers other than investment funds. The CSA said the model is not mandatory, and each issuer can decide whether it is appropriate in its circumstances.
For the wealth professionals whose clients hold these securities, the practical change is in how the disclosure arrives. Under the model, an issuer is treated as having provided electronic access once it files a document on SEDAR+, issues and files a news release on SEDAR+ within one calendar day announcing that the document is accessible, and - if it has a website - posts the document or a direct link within two calendar days. The news release must also flag that investors can sign up for SEDAR+ email notifications, that a copy can be requested, and that standing instructions will continue to be followed.
That last point matters for advisors fielding client questions. The CSA said the Access Model does not affect an investor's ability to request CD documents in electronic or paper form. Where an investor has given standing instructions to an intermediary to receive documents a certain way, those instructions continue to be followed even if the issuer opts into the model.
The CSA framed the move as keeping pace with investor behavior. "This Access Model is consistent with the general evolution of our capital markets and recognizes that investors are increasingly accessing and consuming information electronically," said Stan Magidson, CSA Chair and Chair and CEO of the Alberta Securities Commission, in the announcement.
The amendments cap a long process. The CSA published a consultation paper on the idea on January 9, 2020, proposed rules for prospectuses and CD documents on April 7, 2022, and brought the prospectus access model into force on April 16, 2024. After commenters raised concerns about the effect on retail investors, the regulators republished the CD document proposal on November 19, 2024. During that second comment period, the CSA received submissions from 15 commenters, all of whom expressed general support, the notice said.
In response, the CSA loosened several timing requirements - giving issuers one calendar day rather than the same day to issue the news release, and two calendar days to post on their website. It also removed a proposed requirement that issuers put out a news release at least 25 calendar days before ceasing to use the model, and clarified that no stand-alone news release is required.
In Ontario, the rule materials were delivered to the Minister of Finance on June 24, 2026, the notice said. If the minister approves them or takes no action by August 23, 2026, they take effect September 22, 2026.
The full text of the CSA Notice of Amendments and Changes to Implement an Access Model for Certain Continuous Disclosure Documents of Non-Investment Fund Reporting Issuers is available on CSA members' websites, including at https://www.osc.ca/sites/default/files/2026-06/csa_20260625_51-102_amendments-access-model.pdf.
