Dealers warn sudden AP fee increase strains budgets and risks investor access, call for regulatory overhaul
A sudden 20 percent hike in regulatory fees for Approved Persons has caught Canada’s investment dealers off guard, raising concerns about budget disruption, fee duplication, and regulatory transparency.
The Securities and Investment Management Association (SIMA) has voiced strong opposition in principle to the Canadian Investment Regulatory Organization’s (CIRO) proposal to raise the annual AP fee from $250 to $300.
SIMA argues that the timing of the increase—just months after CIRO’s new Integrated Fee Model took effect—has blindsided firms that have already finalized their 2026 budgets.
The association warns that such unanticipated costs can undermine dealers’ ability to serve clients and invest in innovation.
“While we understand that CIRO needs to operate on a cost-recovery basis, this unexpected fee increase places undue financial burden on dealers, affecting their ability to serve clients effectively,” said Andy Mitchell, President and CEO of SIMA.
He called for CIRO and the Canadian Securities Administrators (CSA) to work with industry stakeholders to create a transparent, fair, and sustainable fee model that supports market efficiency and protects investor access to advice.
SIMA’s submission also highlights concerns about fee duplication, noting that the lack of coordination between CIRO and CSA fee structures could reduce market access and discourage innovation.
The association commended Quebec’s Autorité des marchés financiers (AMF) for its proactive approach in adjusting regulatory fees to avoid duplication, and urged other regulators to follow suit.
Beyond the fee increase itself, SIMA criticized the short 30-day consultation period and called for procedural improvements.
The association recommends eliminating redundant registration steps when advisors move between mutual fund and investment dealers, and establishing clear service standards for registration approvals—citing recent delays that have hampered business efficiency.
Despite its strong objections, SIMA acknowledges the need for CIRO to remain financially viable and does not oppose the fee increase outright.
Instead, it urges a collaborative approach to regulatory fee-setting, emphasizing the need for predictability and fairness in a rapidly evolving investment landscape.
