CSA Publishes For Comment Proposed Amendments To Implement An "Access Equals Delivery" Model For Certain Continuous Disclosure Documents

On November 19, 2024, the Canadian Securities Administrators (the "CSA") published for comment further amendments (the "Revised Proposal") to its initial proposal published in April 2022 (the "Initial Proposal") to implement an "access equals delivery" model for continuous disclosure documents. The Revised Proposal would allow reporting issuers (other than investment funds) to provide electronic access to their annual and interim financial statements and related management's discussion & analysis (collectively, the "CD Documents") instead of following the current delivery requirements under securities legislation.

Background on the "Access Equals Delivery" Model

In January 2020, the CSA began a consultation process to solicit feedback on modernizing delivery requirements for certain disclosure documents. On April 17, 2022, the CSA published for comment its Initial Proposal which proposed amendments to implement an "access equals delivery" model for prospectuses