CSA Publishes Proposed Amendment to Insider Reporting Requirements for Investment Funds and Structured Products
Summary
The Canadian Securities Administrators (CSA) published a notice and request for comment on proposed amendments to Part 9 of National Instrument 55-104, which governs insider reporting requirements. The proposed changes would clarify the reporting regime for transactions involving investment funds and structured products such as structured notes, American Depositary Receipts, and Canadian Depositary Receipts based on securities of the reporting insider's reporting issuer. The 60-day comment period closes June 8, 2026.
What changed
The CSA has published a proposed amendment to National Instrument 55-104 that would clarify insider reporting requirements for transactions involving investment funds and certain structured products. The amendment targets transactions in structured notes, American Depositary Receipts (ADRs), and Canadian Depositary Receipts (CDRs) that are based on securities of the reporting insider's own reporting issuer. The proposed changes aim to provide clearer guidance on when these products trigger insider reporting obligations.
Reporting insiders, public companies, and investment fund managers should monitor this consultation closely. If finalized, the amendments may require updates to compliance programs and reporting systems for those dealing in these specific financial instruments. Stakeholders have until June 8, 2026 to submit feedback on the proposed changes.
What to do next
- Review the proposed amendments to Part 9 of NI 55-104 affecting insider reporting for investment funds and structured products
- Assess whether current reporting practices for structured notes, ADRs, and CDRs need adjustment
- Submit comments to CSA 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.
Published: April 9, 2026 CSA 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
This link will open in a new window using the method set out in the notice, which is available on CSA members’ websites
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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
[email protected]
Debra Chan
Ontario Securities Commission
[email protected]
For investor inquiries, please contact your local securities regulator
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