SIMA's July 2026 submission calls for CERTS as the prescribed reporting system and individual-level CE accountability
The Securities and Investment Management Association (SIMA) is calling on the Canadian Investment Regulatory Organization (CIRO) to take a more practical, efficient approach to harmonizing continuing education requirements for mutual fund and investment dealers across Canada.
In a July 15, 2026 submission responding to CIRO’s phase 2 consultation on continuing education harmonization, SIMA said the regulator has a genuine opportunity to modernize the framework. But it warned that some proposals do not adequately reflect how firms and approved persons actually operate.
Andy Mitchell, President and CEO of SIMA in Toronto, said the framework should reduce unnecessary burden, preserve individual-level accountability, and rely on systems already working well for the industry.
A single approach to continuing education: a long time coming
The push to harmonize CE requirements has been in motion since 2021. At that time, the Canadian Securities Administrators (CSA) published a position paper calling on the then-new self-regulatory organization to streamline continuing education across all members.
CIRO was formed on January 1, 2023, through the amalgamation of the Investment Industry Regulatory Organization of Canada (IIROC) and the Mutual Fund Dealers Association of Canada (MFDA). It inherited two distinct CE programs with different cycles, credit structures, and reporting systems. Harmonizing them became a formal commitment in CIRO’s 2025 annual priorities, according to CIRO’s published strategic plan.
Phase 1 of that harmonization was originally planned for January 1, 2026. After industry feedback requested a longer timeline, CIRO delayed Phase 1 and decided to implement both phases at the same time.
The Phase 2 consultation opened in April 2026, with a comment deadline of July 15, 2026 – the same date SIMA filed its submission.
CERTS as the prescribed reporting system
One of SIMA’s central recommendations is that CIRO designate CERTS as the prescribed system for reporting continuing education credits.
CERTS – the CE Reporting and Tracking System – has been in use under the former MFDA framework since the mutual fund dealer CE program launched in December 2021, according to CIRO’s published CE program update. SIMA argues that CERTS offers greater functionality, better tracking, and lower administrative burden than the alternative CIRO is considering.
The association also recommends shifting the obligation to complete and report CE from dealers to approved persons directly. SIMA says this approach would improve accountability and bring the framework in line with professional practice in other regulated fields.
This aligns with the broader direction CIRO has signalled for its integration agenda. CIRO’s 2027 agenda includes Phase 2 amendments to complete CE harmonization across mutual fund and investment dealer registrations. This covers credits, cycles, exemptions, proration, reporting, and scope.
Additional recommendations for CE harmonization
Beyond the reporting system, SIMA is pushing for several other changes to the proposed framework.
The association recommends retaining the term “credits” rather than “hours” for consistency with other regulators. It also calls for clear rules on proration, exemptions, and accreditation – areas it says remain unclear in the current consultation paper.
On timing, SIMA recommends starting the two-year CE cycle on December 1 rather than January 1. This would align more closely with the former MFDA cycle, which ended November 30. SIMA is also asking for an 18-month transition period to give firms and advisors enough time to adapt.
CIRO’s new proficiency model and first official exams launched in January 2026, signalling the pace of regulatory change already underway.
Broader concerns about operational fit
SIMA said it supports the goal of a harmonized CE framework in principle. Its concern is that CIRO’s proposals do not go far enough in accounting for the proportionality of the rules or the operational realities of registrants.
The submission also raises questions about whether the proposed accreditation structure recognises designations and programs already in use across the industry.
Advisors looking for context on how CE obligations intersect with registration categories can refer to CSI’s new firm training program, which launched to meet CIRO’s updated proficiency expectations in early 2026.
CIRO has not yet announced a timeline for publishing its final Phase 2 CE rule amendments.
