CSA Introduce Access Model For Financial Statements And MD&A

On June 25, 2026, the Canadian Securities Administrators (the “CSA”) published final amendments to National Instrument 51-102 – Continuous Disclosure Obligations and National Instrument 54-101 – Communication with Beneficial Owners of Securities of a Reporting Issuer, together with amendments to the related companion policies (collectively, the “Final Amendments”). The Final Amendments introduce an optional access model (the “Access Model”) that permits non-investment fund reporting issuers to satisfy certain requirements to deliver annual financial statements, interim financial reports and related management’s discussion & analysis (collectively, the “Financial Documents”) to investors by providing electronic access to those documents.