New CSA blanket order changes what advisers must report - but only if they meet the conditions
Canadian securities regulators have exempted registered advisers from certain retail client-reporting requirements for institutional accredited investors and related overflow accounts.
The Canadian Securities Administrators published Coordinated Blanket Order 31-935 on June 25, 2026, giving advisers who serve institutional clients relief from reporting rules designed for retail investors.
The relief applies to two groups defined in the order: "institutional accredited investors" and "overflow accounts" of entities related to institutional clients. For those accounts, advisers no longer have to deliver the full set of retail client reports required under National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations, the rule known as NI 31-103.
That rule normally requires registered advisers and dealers to give clients prescribed account information - relationship disclosure information, account statements, cost and compensation reports, and performance reports. Accounts of "non-individual permitted clients" were already carved out, because the CSA treats those institutional investors as recipients of comprehensive, tailored reporting that makes the retail package redundant.
The gap, according to the CSA, was that some institutional clients and related accounts do not meet the financial threshold to qualify as permitted clients - leaving advisers who specialize in the institutional segment on the hook for retail-style reporting anyway. The CSA said it received comments from registered advisers asking for similar relief, and that a significant number of firms focused on institutional investors were seeking it. The regulator decided a blanket order was the most appropriate way to provide it.
The relief is not a clean exit from reporting. Advisers must still provide "institutional client reporting" that the CSA describes as substantially similar to the retail requirements but tailored to an institutional client's needs. Each institutional accredited investor and overflow account holder has to be told it will not receive the retail reporting it would otherwise have been entitled to, and must be given an explanation of what the institutional reporting contains. Advisers that intend to rely on the order must provide notice to the CSA and comply with all other conditions set out in the relief.
The CSA noted that while the outcome is the same across participating jurisdictions, the wording of each province's or territory's order may differ, because each must fit within local securities legislation.
The relief took effect June 25, 2026. It will expire once regulatory or legislative amendments addressing substantially the same subject matter come into force. In Ontario, it expires on the earlier of that date or December 25, 2027 - 18 months after the order - unless the Ontario Securities Commission extends it.
Questions can be directed to staff at the participating commissions, including the British Columbia Securities Commission, the Alberta Securities Commission, the Financial and Consumer Affairs Authority of Saskatchewan, the Manitoba Securities Commission, the Autorité des marchés financiers, the Ontario Securities Commission, the Financial and Consumer Services Commission of New Brunswick, and the Nova Scotia Securities Commission.
