CSA Proposes Amendment to Insider Reporting Requirements for Structured Products
Summary
The Canadian Securities Administrators published a notice and request for comment on a proposed amendment to National Instrument 55-104 Part 9, clarifying insider reporting obligations for transactions involving investment funds and structured products including structured notes, American Depositary Receipts, and Canadian Depositary Receipts based on the reporting insider's reporting issuer securities. The 60-day comment period closes June 8, 2026.
What changed
The CSA has proposed an amendment to National Instrument 55-104 Part 9 to clarify insider reporting requirements for transactions involving investment funds and structured products such as structured notes, American Depositary Receipts (ADRs), and Canadian Depositary Receipts (CDRs) that are based on securities of the reporting insider's reporting issuer. The amendment aims to address gaps in the existing regime by providing clearer guidance on when and how reporting insiders must report these types of transactions.
Reporting insiders engaged in investment fund transactions or dealings in structured products tied to their reporting issuer's securities will need to ensure their compliance systems can capture and report these transactions under the clarified requirements. Public companies and investment funds should review their insider reporting policies and procedures to incorporate the proposed clarifications once finalized.
What to do next
- Review proposed amendment to NI 55-104 Part 9
- Assess current insider reporting practices for investment fund and structured product transactions
- Submit comments by June 8, 2026
Archived snapshot
Apr 10, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
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News Release
CSA publishes proposed amendment to insider reporting requirements for comment
- ### Date:
2026-04-09
- ### Number:
2026/022
TORONTO – The Canadian Securities Administrators (CSA) today published a notice and request for comment on a proposed amendment to Part 9 of National Instrument 55-104 Insider Reporting Requirements and Exemptions.
The proposed amendment is intended to clarify the insider reporting regime applicable to transactions involving investment funds, and certain structured products, such as structured notes, American Depositary Receipts and Canadian Depositary Receipts, that are based on securities of the reporting insider’s reporting issuer.
The CSA welcomes feedback on the proposed amendment. The 60-day comment period closes June 8, 2026. Stakeholders are encouraged to submit their comments using the method set out in the notice, which is available on CSA members’ websites.
The CSA, the council of securities regulators of Canada’s provinces and territories, coordinates and harmonizes regulation for the Canadian capital markets.
For media inquiries, please contact:
| Ilana Kelemen
Canadian Securities Administrators
media@acvm-csa.ca |
| Debra Chan
Ontario Securities Commission
media_inquiries@osc.gov.on.ca |
For investor inquiries, please contact your local securities regulator.
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