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CSA Proposes Amendment to NI 55-104 Insider Reporting Requirements for Investment Funds and Structured Products

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Summary

The Canadian Securities Administrators (CSA) published a proposed amendment to Part 9 of National Instrument 55-104 Insider Reporting Requirements and Exemptions on April 9, 2026. The proposed amendment is intended to clarify insider reporting requirements applicable to transactions involving investment funds and structured products, including structured notes, American Depositary Receipts, and Canadian Depositary Receipts that are based on securities of the reporting insider's reporting issuer. The 60-day comment period closes June 8, 2026.

What changed

The CSA published a proposed amendment to Part 9 of National Instrument 55-104 to clarify insider reporting requirements for transactions involving investment funds and 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 amendment targets clarification of the existing regime rather than fundamental changes to reporting obligations.

Affected parties including public companies, investors, and other market participants subject to insider reporting requirements should review the proposed changes and consider submitting comments by the June 8, 2026 deadline. The clarification may affect how reporting insiders structure and report transactions involving these specific product types.

What to do next

  1. Submit comments on the proposed amendment by June 8, 2026
  2. Use the method set out in the notice on CSA members' websites for comment submission

Archived snapshot

Apr 16, 2026

GovPing 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.

For Immediate Release

April 9, 2026

CSA publishes proposed amendment to insider reporting requirements for comment 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,

  1. 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:

For investor inquiries, please contact your local securities regulator.

Debra Chan Ontario Securities Commission Ilana Kelemen media_inquiries@osc.gov.on.ca Canadian Securities Administrators media@acvm-csa.ca

Named provisions

Part 9 - Insider Reporting Requirements and Exemptions

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Last updated

Classification

Agency
CSA
Published
April 9th, 2026
Comment period closes
June 8th, 2026 (53 days)
Compliance deadline
June 8th, 2026 (53 days)
Instrument
Consultation
Legal weight
Non-binding
Stage
Consultation
Change scope
Substantive

Who this affects

Applies to
Public companies Investors Financial advisers
Industry sector
5231 Securities & Investments
Activity scope
Insider reporting Investment fund transactions Structured products trading
Geographic scope
Canada CA

Taxonomy

Primary area
Securities
Operational domain
Compliance
Compliance frameworks
SOX
Topics
Corporate Governance Financial Services

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