New Limits, New Life: Understanding CSA's Blanket Order 45-935

Canada's capital markets are undergoing a period of regulatory modernization. The Canadian Securities Administrators ("CSA") have introduced a series of targeted reforms aimed to: (i) support the competitiveness of Canada's capital markets by making it more efficient for companies to raise capital, (ii) ensure the regulatory environment remains responsive to the needs of market participants, and (iii) facilitate capital raising through the exempt market. Among the CSA's developments is Blanket Order 45-935 (the "Blanket Order") – an update to the Listed Issuer Financing Exemption ("LIFE"), which significantly expands capital-raising limits.

The LIFE Exemption Overview

LIFE was initially introduced in November 2022 under National Instrument 45-106 (the "Instrument") to help publicly listed companies raise capital more efficiently. Instead of having to prepare a full prospectus, which can be costly and time-consuming, LIFE allows eligible issuers to distribute