The Canadian Advocacy Council (CAC) supported the Ontario Securities Commission’s (OSC) proposed machine-readable regulatory dataset, noting that it could reduce compliance costs, lower barriers to entry and support useful regulatory technology. It recommended publishing the dataset as derivative and non-authoritative, rather than as a substitute for enacted law. The CAC also urged the OSC to design the dataset for AI and automated use with clear metadata on authority, currency and provenance; align it with established legislative data standards; and provide open access to the core dataset. It further recommended a clear correction process, disclosure of any commercial partner’s role(s) and confirmation of OSC ownership of annotations and taxonomy.

The CAC supported the Canadian Investment Regulatory Organization’s (CIRO) Rule Consolidation Project and its move toward harmonized, principles-based regulation across Investment Dealers and Mutual Fund Dealers. Its main concern was that reporting, investigation and complaint-handling requirements could be inconsistently understood and applied unless CIRO issued interpretive guidance timed to be effective for when the rules take effect. The CAC supported competency-based supervisor proficiency requirements and did not identify implementation impacts that would prevent Mutual Fund Dealer Members from complying on time. It also recommended a post-implementation review 18 to 24 months after implementation to assess consistency, operational impacts and whether the rules were achieving their objectives.

The CAC supported CIRO’s Phase 2 Continuing Education (CE) Harmonization Proposals, including calendar-year cycle alignment, proration, harmonized definitions, extended reporting timelines, the shift from “credits” to “hours” and expanded continuing education requirements for senior executives. However, the CAC cautioned that the framework appeared overly focused on reducing burden and did not sufficiently replace the eliminated accreditation, audit and topic-list mechanisms with new quality safeguards. The CAC recommended recurring CIRO-developed Continuing Education content on key topics, guidance on appropriate continuing education by registration category and mechanisms to verify participant understanding. It also urged CIRO to add firm-level accountability for systemic continuing education failures and to preserve continuing education compliance status at departure through the National Registration Database rather than eliminating terminated-individual reporting.