CIRO Proficiency Exemption Requests

1. Overview

Proficiency standards are a cornerstone of the CIRO regulatory regime. High proficiency standards play a key role in investor protection and the integrity and efficiency of capital markets. CIRO establishes, maintains and promotes high proficiency standards and a robust proficiency regime in the investment industry.

An applicant for approval must meet prescribed proficiency requirements. Guidance Notice GN-9200-21-001 outlines Registration staff’s (Staff) approach to reviewing suitability in accordance with the “fit and proper” criteria set out in section 9204.1 Dealers are expected to put forward applicants for approval who meet CIRO proficiency requirements.

Where an individual has completed an alternative proficiency, which may include an alternative educational course, training or experience, a dealer may choose to file a proficiency exemption request on behalf of the applicant for consideration by CIRO in accordance with section 9206. Where an exemption is filed, the onus is on the dealer and applicant to provide the information needed for Staff to complete its review in order to determine whether the alternative is acceptable and, at a minimum, equivalent to a prescribed proficiency requirement in determining whether to grant the exemption or extension.

Dealers who wish to request a proficiency exemption on behalf of an approval for applicant should consider the information provided in this Guidance Note prior to seeking an exemption. Dealers should also be familiar with the existing exemption provisions outlined in Guidance on the new CIRO Proficiency Model for Approved Persons of Investment Dealers – Exemptions, Recognition, Transition and Validity Provisions.

1.1 Scope

An individual or a dealer on their behalf may apply for an exemption from the proficiency requirements under Rule 2600, or for an extension of or exemption from a continuing education requirement under Rule 2700.2 CIRO may grant an exemption or extension in accordance with any standards in the relevant rule, subject to any terms and conditions it considers appropriate.3 The guidelines in this notice focus on how to file an exemption request from a pre-approval proficiency requirement in subsection 2603(1).

2. Prescribed CIRO exams

Staff will review and approve proficiency exemption requests from completing a prescribed CIRO exam on a case-by case basis. A dealer who seeks an exemption on behalf of an individual must clearly demonstrate how completion of an alternative educational course, training or experience is, at least, equivalent to the requirement for approval. Upon review, Staff will specifically consider whether the alternative is at least equivalent to the learning outcomes covered in the syllabus of any appliable CIRO exam as demonstrated by the comparative analysis requirement described in section 3.1.

Each CIRO exam is supported by a detailed syllabus with defined learning outcomes. Staff’s review of a proficiency exemption request from completing a prescribed exam will take into consideration how clearly an applicant is able to demonstrate alignment with the relevant syllabus applicable to the prescribed exam.

Staff may consider a proficiency exemption request based on alternative experience or education in the place of completing a CIRO exam. The information to be provided to support such a request will be reviewed on a per case basis to determine if the experience put forward is an acceptable alternative and at least, equivalent to the learning outcomes within the syllabus applicable to the prescribed exam.

Staff will not support an exemption based on an educational course or materials intended as preparatory for passing a CIRO exam

2.1 Relevant education and experience

In general, relevant education and experience put forward by a dealer needs to be acceptable to the CIRO.4 Dealers are in the best position to assess the specifics of an individual’s education and experience, CIRO Registration staff will assess the suitability of the education and experience as part of their gatekeeping responsibilities. Guidance on relevant education and experience factors are set out for dealers to consider as they assess the relevance of an individual’s education and experience.

We would not support an exemption application from relevance. Dealers have the responsibility to ensure that an individual’s education or experience is relevant.

3. CIRO information requirements

A dealer must file a proficiency exemption request on behalf of an individual and pay the applicable fee through the National Registration Database (NRD). Staff require sufficient information in order to review and approve a request that, at a minimum, demonstrates the equivalency of an alternative education, experience or training to a prescribed requirement. The onus rests on the dealer to provide sufficient information and analysis. For an exemption from a CIRO exam, staff will require an analysis that compares the alternative to the applicable syllabus. The comparative analysis component is essential to demonstrating equivalency as discussed further in section 3.1. A proficiency exemption request based on an individual’s experience will require a similar analysis as set against the learning outcomes.

Where applicable, a request should include:

• official transcripts or completion certificates, which include course/program name and provider, and
• other documents that may assist with the review, such as reference letters that explain and confirm an individual’s experience.

Dealers are expected to ensure the information provided satisfies disclosure and hiring due diligence requirements set out under securities legislation.5

3.1 Comparative Analysis

When a dealer files an exemption request on the basis of equivalent education or experience, a comparative analysis is essential to demonstrating equivalency in order to support the request. Staff cannot review and approve a request if a dealer only provides simple lists or descriptions of alternative proficiency without providing a detailed comparative analysis. In other words, such a proficiency exemption request cannot be reviewed based upon simple information or documents alone, such as a resume or a standard job description. Dealers may provide Staff with a comparative analysis in several forms, including tables, charts or descriptive paragraphs provided they clearly demonstrate equivalency.

3.2 Timeframe for review

Staff aim to complete reviews for proficiency exemption requests on a timely basis. Review time may vary with each application as they are conducted on a case-by-case basis. However, dealers should be aware that a review may be delayed in the event of the following:

• multiple exemptions being requested for the same individual,
• incomplete information or insufficient detail, and
• insufficient analysis to demonstrate that the information provided is an acceptable alternative to the required proficiency.

3.3 Deficient applications

An exemption application is deficient if additional information is still required from the dealer or individual. Staff will contact the dealer’s Authorized Firm Representative (AFR) with a request for any missing information. The AFR is responsible for obtaining this information from the dealer and/or individual in a timely manner.

Staff requests for missing or outstanding information will include a due date. Staff expects responses from the dealer by the due date, otherwise Staff will not proceed with a complete review of the request when information is still deficient or outstanding past this date. After the due date, the dealer will be required to file a new submission on NRD and pay the requisite fee.

4. Previously mandated proficiencies

As of January 1, 2026, Canadian Securities Institute (CSI) courses are no longer an acceptable proficiency under IDPC. Individuals should refer to section 2629 – Transition from courses prescribed prior to January 1, 2026 for applicable use and conditions relating to CSI courses, as they apply to the new CIRO requirements.

For all other CSI course requirements that apply as of January 1, 2026 in section 2605. Mutual funds only Registered Representatives and Investment Representatives, please refer to the previous Guidance Note GN-2600-21-007, which may be appropriate for exemptions from CSI course requirements still in effect for investment dealers and their Approved Persons.

5. Applicable Rules

This Guidance Note relates to IDPC:

• Rule 2600,
• section 9203,
• section 9204, and
• section 9206.

6. Previous guidance note

Guidance Note GN-2600-21-007 IIROC Registration – Proficiency Exemption Requests

• 1CIRO’s approval regime is similar to the registration regime set out in securities legislation.
• 2See Guidance on IIROC’s Continuing Education Program (GN-2700-21-001)
• 3Section 9206
• 4Clause 2603(1)(ii)
• 5Section 5.1(1) of NI 33-109 to make reasonable efforts to ensure the truthfulness and completeness of registration information