Guidance on Relevant Education and Experience Requirements

1. Background

The Proficiency Model for Approved Persons under the Investment Dealer and Partially Consolidated (IDPC) Rules,1 effective January 1, 2026, prescribes minimum education or experience requirements that an applicant for approval must have before CIRO will grant approval in the following categories:

• Registered Representative,
• Associate Portfolio Manager,
• Portfolio Manager,
• Supervisor,
• Ultimate Designated Person and Executive,
• Chief Compliance Officer, and
• Chief Financial Officer.

All Approved Persons must complete prescribed CIRO exam and training requirements.

2. Purpose of education or experience requirements for Approved Persons

As set out in Bulletin 24-0206, the objective of introducing certain education or experience requirements is to enhance our proficiency regime to better carry out our public interest mandate, which includes investor protection. We also considered the importance of access to advice for the investing public and not setting the bar so high that dealers will not be able to hire individuals as needed to support their business. While it is important to ensure that our model is such that it can continue to attract individuals to carry out regulatory functions on behalf of dealers, it is equally important that those who have core regulatory responsibilities have a certain level of education or experience before undertaking some of these roles and responsibilities.

In this Guidance Notice we set out key factors for dealers to consider as they assess the relevancy of an individual’s education or experience before submitting an application for approval to ensure compliance with the proficiency principle in IDPC section 2602. IDPC rules for proficiency include minimum education and experience requirements for the Approved Person categories listed in section 1, above.2 This is in addition to the general requirement for dealers to ensure that an individual does not perform an activity that requires approval unless the individual has the education, training and experience a reasonable person would consider necessary to perform the activity competently.3

Generally, the following are important considerations when assessing an individual’s education, training and experience:

• the applicable CIRO approval category, including client and product types,
• the dealer’s business model as it applies to the approved role, and
• the activities and responsibilities of the Approved Person.

Dealers have a responsibility to ensure compliance with the proficiency principle and specific education and experience requirements. While we are not mandating specific types of education or experience, the education and experience have to be such that comply with the proficiency principle and reflect the objective of the education and experience requirements, which is to ensure candidates have the maturity to serve the investing public and analytical and communication skills to carry out their regulatory responsibilities.

While dealers are in the best position to assess the specifics of an individual’s education or experience for their business needs, we are providing guidance here to offer context on what may be relevant education or experience.

In carrying out its gatekeeping responsibilities, CIRO Registration staff (Staff) will assess the suitability of the education and experience put forward as part of their fit and proper review to confirm applicability to the activities and responsibilities of the Approved Person category. In carrying out its gatekeeping responsibilities, Staff may request additional information relating to an applicant’s education or experience.

3. Registered Representatives (RRs)

RRs are approved to trade or advise on securities, and/or derivatives with the investing public in Canada. Considering their direct relationship with the public, RRs have an integral role in and impact on our capital markets. Effective January 1, 2026 newly approved RRs are required to either have a relevant diploma or degree from an accredited post-secondary institution, or minimum four years of relevant experience. These requirements are set to ensure that those who are on the frontline providing advice to clients have the appropriate level of education and experience.

For RRs, the core objective of mandating a certain level of education or experience is to ensure they have the maturity to serve the investing public, and ability to apply the necessary analytical and communication skills to carry out their regulatory responsibilities. We are not prescribing a list of education and experience as we recognize the value of diverse education backgrounds. Instead, we take a more principle-based approach to baseline education and experience, which will allow for continued and increased diversity within the population of those who serve the investing public. We recognize that RRs have varied backgrounds, including from other careers, and may have been educated in another country so our goal is to ensure that we raise the bar without creating unnecessary barriers to entry.

Dealers should consider the education and experience of the individual from the perspective of compliance with the proficiency principle and whether they have obtained the requisite maturity, analytical and communication skills to serve the investing public and discharge their responsibilities of a RR.

3.1 Relevant Education

Dealers need to consider relevance of an applicant RR’s education and experience from the perspective of whether they have obtained the requisite maturity, analytical and communication skills to serve the investing public and to discharge the responsibilities of a RR. It is important to keep in mind the proficiency principle in section 2602. In considering the relevant education and experience of an individual within the context of the role of an RR, the applicable competency profiles may also be a useful tool.

CIRO does not prescribe the type of education required. To assist dealers with the types of education that may be relevant, below we have listed some examples of degrees that may be considered relevant:

• Bachelor of Architecture
• Bachelor of Arts (i.e., Humanities, Sociology, Psychology, Geography)
• Bachelor of Commerce (i.e., Management, Accounting, Economics, Finance)
• Bachelor of Computer Science & Technology
• Bachelor of Education
• Bachelor of Engineering and other applied Mathematics
• Bachelor of Science (i.e., Physical, Health, Medical, Geology)
• Bachelor degree in health professions, including:
  • Kinesiology
  • Physiotherapy
  • Social Work, and
• Bachelor of Laws.

We also provide examples of diplomas in the following subjects that may be considered relevant:

• Accounting,
• Business Management,
• Finance/Financial Planning/Financial Services,
• Insurance,
• Healthcare
• Law Clerk/Paralegal, and
• Engineering Technology.

It is important to note that these lists are not exhaustive or prescriptive. A diploma or degree from an accredited post-secondary institution, whether domestic or international, may be relevant. As part of their hiring due diligence, dealers need to assess which educational backgrounds align most closely with their specific business needs and the RR’s role. CIRO staff may require further information on this consideration in exercising their gatekeeper function when reviewing an application for approval.

3.2 Relevant Experience

An individual seeking approval to become a RR may rely on at least four years of relevant experience to satisfy the baseline requirement. Dealers need to consider an individual’s experience from the perspective of consistency with the proficiency principle and whether they have obtained the requisite maturity, analytical and communication skills to serve the investing public and discharge their responsibilities of a RR. Below, we have listed examples of organizations that may qualify a RR with relevant experience:

• Investment Dealers/Mutual Fund Dealers/Foreign Securities Dealers
• Investment Fund Managers
• Banks/Credit Unions/Trust Companies
• Insurance Companies
• Mortgage Brokers
• Provincial, Federal domestic or foreign governments, institutions or administrative bodies
• Professional associations or designations (e.g., Engineering, Accounting, Legal, Teaching)

This list is not intended to be exhaustive. Same as with education, as part of their hiring due diligence, dealers need to assess which experience backgrounds align most closely with their specific business needs and the RR’s role. CIRO staff may require further information on this consideration in exercising their gatekeeper function when reviewing an application for approval.

4. Supervisor - Relevant Experience

A dealer must appoint as many Supervisors as necessary to properly supervise its employees and Approved Persons taking into account the scope and complexity of its business. The dealer’s responsibility includes taking reasonable steps to ensure all of its Supervisors are fully proficient and understand the products that employees and Approved Persons under their supervision trade in or advise on, as well as the services these employees and Approved Persons provide. Each Supervisor must fully and properly supervise each employee and Approved Person under their authority in accordance with the supervisory responsibilities assigned to the Supervisor, the dealer’s policies and procedures, and CIRO requirements and securities laws.

Supervisors must have a minimum two-year relevant experience4. For Supervisors, relevant experience will depend on the specific supervisory role, activities, and the dealer’s business model. A dealer is responsible for thoroughly assessing each individual’s experience to ensure they can effectively fulfill their supervisory responsibilities.

The IDPC rules include various types of Supervisors. Keeping in mind the IDPC rules, including Rule 3900, dealers should continue to provide details on the specific area(s) of supervision when filing an application for approval.

For designated supervisory roles, such as for opening of new accounts and pre-approval of advertising, sales literature, and correspondence, relevant experience may include supervisory, compliance and operational experience at one or more of the following:

• Investment Dealers (i.e., in a registered capacity such as Investment Representative or Registered Representative),
• Mutual Fund Dealers,
• CSA Portfolio Managers (as regulated by a member of the Canadian Securities Administrators), and
• Entities regulated by recognized foreign regulatory organizations, such as the Financial Industry Regulatory Authority (FINRA).

For supervisor roles that involve supervision of account activity and trading in particular, dealers need to consider the type of account activity and trading experience that the applicant for approval as a Supervisor has, within the context of what is listed above. For example, an individual with compliance experience at a mutual dealer would not be considered to have the relevant experience for being a Supervisor overseeing derivatives accounts or trading.

For a Supervisor of Research, the following may be relevant experience:

• an equity research analyst or associate research analyst role,
• an investment banking role, covering mergers and acquisitions (M&A) or capital markets,
• financial modeling, valuation techniques, and forecasting roles gained through experience involving deal analysis, due diligence, or financial advisory, and
• roles involving risk management within the investment banking / capital markets.

The CFA Charter may be acceptable for this type of Supervisor as the qualification requires satisfying at least 4,000 hours of experience in a minimum of 36 months, which could be considered experience acceptable to the Corporation, where relevant to the role.

For a Supervisor of Managed Accounts, the following is generally considered relevant experience:

• RR, APM or PM experience at a CIRO investment dealer or a similar CSA Portfolio Manager role, which may include identifying managed account conflicts of interest related requirements.

Individuals who typically conduct these types of activities have experience in compliance, operations or supervision, where needed, to identify and review issues of non-compliance.

5. Executive - Relevant Experience (including Ultimate Designated Person)

A dealer must designate as many Executives as necessary to ensure compliance with CIRO requirements, taking into account the scope and complexity of its business. This includes assigning responsibility for each significant area of risk within a dealer to an appropriate Executive. Executives are responsible for the review and approval of any policies and procedures relating to their significant area of risk.5

A dealer is responsible for taking reasonable steps to ensure all of its Executives are fully proficient same as Supervisors, as described in section 4 above. Each Executive must supervise and direct the dealer’s activities, and its employees and Approved Persons, in accordance with the areas of their responsibility, to provide reasonable assurance of compliance with CIRO requirements and securities laws.6

Executives, including the Ultimate Designated Person (UDP), must have minimum two years of relevant experience. The requirement is in addition to the requirements in IDPC section 2503.7 For Executives, relevant experience will be based on the category of approval, the responsibilities of the Executive, and the dealer’s type of business. We provide some examples for dealers to consider. These examples are illustrative only, not exhaustive and may include:

• leadership roles at a related or affiliated firm registered with a securities regulatory authority,
• executive roles at an affiliated foreign securities dealer or advisor,
• experience at an affiliated Canadian financial institution, and
• executive responsibility for operations, investment trading, trading activities, or research.

It is the responsibility of the dealer to thoroughly assess an individual’s experience to ensure they can effectively fulfill the Executive responsibilities required.

6. Chief Compliance Officer (CCO)

A dealer must designate a CCO that is responsible for:

• establishing and maintaining policies and procedures to assess compliance by the dealer and individuals acting on its behalf with CIRO requirements and securities laws,
• monitoring and assessing compliance by the dealer and individuals acting on its behalf, and
• promptly escalating matters of non-compliance to the UDP if either the non-compliance creates a reasonable risk of harm to a client, creates a reasonable risk of harm to the capital markets, or the non-compliance is part of a pattern of non-compliance,8
• providing an annual written report to the dealer’s board of directors for the purpose of assessing compliance by the dealer, and its employees and Approved Persons.9

CCOs must have either:

• five years working for an investment dealer or registered advisor,10 or affiliated Financial Industry Regulatory Authority (FINRA) dealer, with at least three years in a compliance or supervisory capacity,11 or
• three years providing professional services in the securities industry, with at least 12 months experience working at an investment dealer or registered advisor in a compliance or supervisory capacity.12

For some dealers, the scale and scope of activities carried out by different operating divisions may require more than one CCO to be designated. Some other dealers may apply a shared CCO model, where a CCO is designated for more than one dealer. In such cases, the shared CCO must be able to demonstrate proficiency to act as CCO for each dealer's business. Typically, before an individual could be approved as a CCO in a shared model, the individual would have to have had prior experience as a CCO.13

7. Chief Financial Officer (CFO)

A dealer must designate a CFO that is responsible for:

• establishing and maintaining policies and procedures relating to CIRO’s financial requirements,
• monitoring adherence to the dealer’s policies and procedures to provide reasonable assurance that it complies with CIRO’s financial requirements,
• identifying any breaches of approved capital usage limits and reporting them as required, and
• promptly reporting to the UDP if there is any indication that the dealer or any individual acting on its behalf may be in non-compliance with CIRO’s financial requirements if either the non-compliance creates a reasonable risk of harm to a client, creates a reasonable risk of harm to the capital markets, or the non-compliance is part of a pattern of non-compliance.14

Upon implementation, CFOs must continue to have a financial accounting designation, finance related university degree or diploma or equivalent work experience as may be acceptable to the Corporation.15 CFO proficiency requirements consider the CFO’s responsibility for the dealer’s compliance with CIRO financial and operational rules set out above. With respect to the equivalent experience, their experience must prepare the individual to address complex financial regulations competently. We will assess these on a case by case basis.

8. Portfolio Managers (PMs)/Associate Portfolio Managers (APMs) – RIME

Upon implementation, an APM must continue to have minimum two years of relevant investment management experience (RIME) acceptable to the Corporation within three years prior to the date of application for approval. A PM must either continue to have:

• If Canadian Investment Manager Designation or Chartered Investment Manager Designation (CIM®) is completed, at least four years of RIME acceptable to the Corporation, of which one year was gained within the three years prior to the date of application for approval,16 or
• If CFA Charter is completed, at least one year of RIME acceptable to the Corporation within the three years prior to the date of application for approval.17

RIME is a requirement for all APM and PM applicants.18 RIME must be clearly outlined to support an application for approval. For example, if the applicant’s experience was obtained from various roles, details relating to those roles and details of relevant investment management activities conducted, including the dates and timeframe of the experience, must be provided.

Staff will assess whether an individual has acquired RIME on a case-by-case basis consistent with the approach outlined in Part 3 of National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (NI 31-103), its Companion Policy (CP) 31-103CP, and CSA Staff Notice 31-332 Relevant Investment Management Experience for Advising Representatives and Associate Advising Representatives of Portfolio Managers.

Dealers are encouraged to review these resources before filing an application for approval.19

9. Filing Requirements on National Registration Database (NRD)

Dealers must disclose education and experience on NRD at the time of filing an application for approval. Dealers should ensure that they are filing information under the correct submission type and in accordance with the appropriate submission type requirements.

An application for approval for an RR specifically requires a dealer to provide details on the applicant’s relevant diploma or degree under item 8. Dealers must select “Other” in the drop-down menu on NRD where Course, examination, designation or other education is presented, and then specify the relevant information (degree, diploma and educational institution) along with the completion date.

To report relevant experience for applicable approval categories, details on relevant experience should be reported under item 10 to avoid processing delays. CIRO may request additional information, as needed, in order to complete application reviews.

10. Applicable Rules

Rule 2600. Proficiency requirements and exemptions from proficiencies

• 1CIRO Proficiency Model for Approved Persons under the IDPC Rules (Rules Bulletin 25-0110, April 17, 2025)
• 2Clause 2603(1)(ii)
• 3Subsection 2602(2)
• 4Clause 2603(1) (d)
• 5Section 1502
• 6Subsection 3909(1)
• 7Dealer Member Executives must meet the applicable proficiency requirements under subclause 2603(1)(ii)(e). Additionally, at least 60% of a Dealer Member’s Executives must have a minimum of five years of experience in the financial services industry, unless a shorter period is approved by the Corporation.
• 8Subsection 3912(1)
• 9Subsection 3915(1)
• 10Currently, the IDPC Rules do not include the term “registered adviser” as reflected in National Instrument 31-103, Registration Requirements, Exemptions and Ongoing Registrant Obligations. We expect to make the necessary housekeeping amendments to update the term.
• 11Paragraph 2603(1)(ii)(f)(I).
• 12Paragraph 2603(1)(ii)(f)(II).
• 13See CSA Staff Notice 31-358 Guidance on Registration Requirements for Chief Compliance Officers and Request for Comments (July 2, 2020).
• 14Subsection 3913(1)
• 15Paragraph 2603(1)(ii)(g)(I).
• 16Paragraph 2603(1)(ii)(c)(I).
• 17Paragraph 2603(1)(ii)(c)(II).
• 18Specific instructions for documenting RIME/experience requirements are found in Form 33-109F4, Schedule F Proficiency, Item 8.4 Relevant securities industry experience.
• 19See e.g., CSA Staff Notice 31-332 – Relevant Investment Management Experience for Advising Representatives and Associate Advising Representatives of Portfolio Managers