What firms submit now will shape who gets the regulator's attention next
The OSC just gave every registrant in Ontario a six-week window to complete the 2026 Risk Assessment Questionnaire - or face the consequences.
The Ontario Securities Commission issued the RAQ on May 6, 2026, with a deadline of June 17, 2026. Portfolio managers, restricted portfolio managers, investment fund managers, exempt market dealers, and restricted dealers all need to file through the OSC's Electronic Filing Portal. Access details went out by email the same day.
Any firm that was active as of December 31, 2025, and did not receive that email should contact [email protected] as soon as possible.
Here is why this matters. The OSC uses the RAQ to decide which firms get a closer look. The data feeds into a risk-ranking system, and firms that rank higher are more likely to land on the regulator's list for an on-site or desk compliance review.
An on-site review means OSC staff at your door, going through the books, records, and documents required under section 19 of Ontario's Securities Act. A desk review is more contained - focused on a specific issue, run from OSC offices using information the firm provides. No on-site visit takes place, and follow-up is limited to written and verbal requests for additional information or clarification.
When a firm does get selected for review, the OSC will generally interview senior management and key employees, examine books and records and financial transactions, assess internal controls, compliance systems, disclosure, marketing practices, and policies and procedures, and discuss and issue a deficiency report outlining areas of non-compliance.
Most of the time, the deficiency report is the end of the road - a formal ask to fix the issues the regulator found. But when staff identify that an individual associated with the firm is responsible for material misconduct or serious non-compliance of securities law, things go further. The OSC can track and monitor a firm or individual, conduct follow-up reviews, impose terms and conditions on registration, refer the matter to its Enforcement Branch, or suspend or revoke registration altogether. Those terms and conditions can mean monthly reporting requirements, restrictions on accepting new clients or new investments from existing ones, or a requirement to hire a compliance consultant to remediate compliance deficiencies.
A firm does have the right to request an opportunity to be heard by the Director before the OSC imposes terms and conditions or moves to suspend or revoke its registration.
The RAQ is not the only reason a firm might end up under review. The OSC also selects firms based on a particular topic of interest or issue, complaints, referrals from other branches or regulators, or random review.
On the dealer side, the Canadian Investment Regulatory Organization handles compliance reviews for the dealing operations of investment dealers, futures commission merchants, and mutual fund dealers. As part of the delegation of registration to CIRO, the OSC will implement an enhanced framework of ongoing oversight of the delegated powers and duties and intends to perform risk-based direct compliance examinations of investment dealers, futures commission merchants, and mutual fund dealers.
For firms working through the questionnaire, the OSC has put out a few resources - frequently asked questions and a user guide, a PDF version of the RAQ for reference, a list of contacts to provide assistance, and information on an outreach webinar scheduled for May 14, 2026. The regulator also publishes annual summary reports covering the results of compliance reviews, common deficiencies identified in the reviews, and suggested best practices.
The full text of the 2026 Risk Assessment Questionnaire and related resources is available at https://www.osc.ca/en/industry/registration-and-compliance/ongoing-requirements/osc-compliance-reviews.
The bottom line for wealth firms in Ontario: the RAQ shapes how the OSC sees you - and how closely it decides to look.
