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ARTICLE · 24 JULY 2026

One Step Closer To Harmonization: CIRO's Proposed Incorporated Approved Person Compensation Model

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The Canadian Investment Regulatory Organization (CIRO) has published rule amendments to harmonize advisor compensation (the Amendments). Following CIRO’s 2024 position paper that consulted on three potential regulatory approaches to allow payment of advisor compensation to advisor-owned corporations for all CIRO-regulated dealer members (Dealers), the Amendments propose to adopt the Incorporated Approved Person compensation option.

CanadaFinance and Banking
Kathryn Fuller
Kathryn Fuller
Melissa Ghislanzoni-Foster
Melissa Ghislanzoni-Foster
Natasha Miklaucic
Natasha Miklaucic
Maureen Doherty
Maureen Doherty
Julie Mansi
Julie Mansi
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The Canadian Investment Regulatory Organization (CIRO) has published rule amendments to harmonize advisor compensation (the Amendments). Following CIRO’s 2024 position paper that consulted on three potential regulatory approaches to allow payment of advisor compensation to advisor-owned corporations for all CIRO-regulated dealer members (Dealers), the Amendments propose to adopt the Incorporated Approved Person compensation option.

In a material shift from the 2024 proposals, under the proposed Amendments, both ancillary activities and regulated Canadian financial services sector activities can be conducted by the advisor’s corporation (Incorporated Approved Person) on behalf of the sponsoring Dealer, subject to certain constraints. CIRO views the proposed Amendments as addressing the lack of flexibility, consistency and tax certainty under the current directed commission model, which will be phased out.

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