CSA Proposes Amendment to Insider Reporting Requirements for Investment Funds and Structured Products
Summary
The Canadian Securities Administrators published a notice and request for comment on April 9, 2026, proposing amendments to Part 9 of National Instrument 55-104 regarding insider reporting requirements. The proposed amendment would clarify insider reporting obligations for transactions involving investment funds and structured products such as structured notes, American Depositary Receipts, and Canadian Depositary Receipts based on securities of a reporting insider's reporting issuer. The 60-day comment period closes June 8, 2026.
What changed
The CSA proposes amendments to Part 9 of National Instrument 55-104 to clarify insider reporting obligations for investment funds and structured products, including structured notes, American Depositary Receipts, and Canadian Depositary Receipts based on securities of the reporting insider's reporting issuer. The amendment targets ambiguity in how the existing insider reporting regime applies to these investment vehicles. Investment funds, structured product issuers, and market participants should carefully review the proposed changes to understand their reporting obligations and provide feedback to the CSA through the consultation process by June 8, 2026.
What to do next
- Review the proposed amendment to Part 9 of National Instrument 55-104
- Assess how the clarified insider reporting rules affect investment fund and structured product transactions
- Submit comments to the 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.
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CSA publishes proposed amendment to insider reporting requirements for comment
April 9, 2026
For Immediate Release
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
[email protected]
Debra Chan
Ontario Securities Commission
[email protected]
For investor inquiries:
For investor inquiries, please contact your local securities regulator.
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