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Capital Markets January 29, 2026 · 8 min read

CSA 2026 Policy Updates: Semi-Annual Reporting Pilot, EMD Reform, and Investment Fund Modernization

CSA 2026년 정책 업데이트: 반기보고 파일럿, EMD 개혁, 투자펀드 현대화

Key Takeaway

The Canadian Securities Administrators (CSA) announced three significant policy changes in early 2026: (1) a Semi-Annual Reporting Pilot (SAR Pilot) for TSXV/CSE venture issuers, (2) the failure of the Exempt Market Dealer (EMD) expanded capital-raising role initiative and subsequent policy review, and (3) modernization of the continuous disclosure regime for investment funds. For Korean companies pursuing a TSXV listing with Rise Partners' support, the reduced reporting burden under the SAR Pilot represents a particularly compelling proposition for smaller Korean issuers.

# CSA 2026 Policy Updates: Semi-Annual Reporting Pilot, EMD Reform, and Investment Fund Modernization

Executive Summary

The Canadian Securities Administrators (CSA) announced three significant policy changes in early 2026: (1) a Semi-Annual Reporting Pilot (SAR Pilot) for TSXV/CSE venture issuers, (2) the failure of the Exempt Market Dealer (EMD) expanded capital-raising role initiative and subsequent policy review, and (3) modernization of the continuous disclosure regime for investment funds. For Korean companies pursuing a TSXV listing with Rise Partners' support, the reduced reporting burden under the SAR Pilot represents a particularly compelling proposition for smaller Korean issuers.

Details

1. Semi-Annual Financial Reporting Pilot (SAR Pilot) — March 19, 2026

The CSA formally adopted a multi-year pilot project allowing eligible venture issuers to voluntarily opt into a semi-annual financial reporting framework ([CSA Official Announcement](https://www.securities-administrators.ca/news/canadian-securities-regulators-announce-adoption-of-semi-annual-financial-reporting-pilot/)). This exempts participants from the Q1 and Q3 interim financial report filing obligations otherwise required under NI 51-102 (Continuous Disclosure Obligations).

Eligibility Criteria ([Dentons Analysis](https://www.dentons.com/en/insights/articles/2026/march/20/canadian-securities-administrators)):

  • Must qualify as a "venture issuer" listed on the TSXV or CSE
  • Must not be listed on the TSX, Cboe Canada, a U.S. exchange, or a foreign exchange other than AIM/AQSE
  • Revenue of C$10M or less based on the most recently audited financial statements
  • Must have maintained Canadian reporting issuer status for at least 12 months
  • Must be current on all periodic and timely continuous disclosure filings

    • Key Impact: Eligible issuers are required to file financial reports only twice per year (at the 6-month and 12-month marks), rather than quarterly. This significantly reduces regulatory compliance costs and administrative burden for smaller venture companies ([Gowling WLG](https://gowlingwlg.com/en/insights-resources/articles/2026/canadian-securities-administrators-launch-semi-annual-financial-reporting-pilot)).

    Investor Protections: SAR Pilot participation does not eliminate all continuous disclosure obligations. Issuers must continue to issue press releases on material changes and disclose material contracts, among other ongoing requirements.

    2. EMD (Exempt Market Dealer) Expanded Role Initiative — Declared Ineffective, January 2026

    The time-limited exemption introduced by the CSA in June 2024 (CSA Coordinated Blanket Order 31-930), which permitted EMDs to participate in selling groups for prospectus offerings, effectively failed — with only two dealers utilizing the exemption ([CSA Feedback Request](https://www.securities-administrators.ca/news/canadian-securities-regulators-provide-update-and-seek-feedback-on-multilateral-initiative-to-support-capital-raising-by-extending-the-role-of-exempt-market-dealers/)).

    The exemption expired on December 20, 2025 and was not renewed. The CSA launched a 60-day comment period (deadline: January 26, 2026) to investigate the root causes of its limited uptake.

    Analysis of Contributing Factors ([Investment Executive](https://www.investmentexecutive.com/uncategorized/emd-exemption-falls-flat-csa-asks-why/)):

  • Whether EMD compensation restrictions deterred participation
  • Whether the absence of electronic settlement access created a structural barrier
  • Whether the inability to provide ongoing advice to investors was a deterrent
  • Whether dealers were even aware of the exemption's existence

    • 3. Investment Fund Continuous Disclosure Modernization — January 22, 2026

    The CSA published final amendments to modernize the continuous disclosure regime for investment funds, aimed at reducing the regulatory burden on fund managers. The final rules are scheduled to come into force on April 22, 2026 ([ASC Announcement](https://www.asc.ca/en/news-and-publications/news-releases/2026/01/22-csa-reduces-regulatory-burden-in-continuous-disclosure-regime-for-investment-funds)).

    4. Strengthened Benchmark Assurance Reporting Requirements — February 19, 2026

    The CSA adopted final amendments to Multilateral Instrument 25-102 (Designated Benchmarks and Benchmark Administrators), clarifying the scope and timing of assurance reporting requirements. Effective date: May 5, 2026.

    5. Fraudulent Website Takedown Initiative

    In a joint initiative with CIRO, the CSA deactivated more than 3,900 fraudulent investment platforms and cryptocurrency scam websites (comprising over 6,900 individual URLs) between June 5 and November 23, 2025 ([OSC Announcement](https://www.osc.ca/en/news-events/news/canadian-securities-regulators-new-capability-disarms-more-3900-fraudulent-investment-websites)).

    6. Consultation on Non-GAAP Financial Measure Disclosure Requirements

    The CSA has launched a consultation on proposed amendments to Non-GAAP and other financial measure disclosure requirements in connection with new IFRS accounting standards ([OSC](https://www.osc.ca/en/news-events/news/csa-launches-consultation-proposed-amendmen)).

    Implications

    1. **Leveraging the SAR Pilot as a Listing Value Proposition**: For Korean companies with revenue below C$10M, the ability to maintain a TSXV listing with only semi-annual reporting — rather than quarterly — is a key selling point for executives at Korean SMEs who are sensitive to the operational demands of public company compliance. The potential for significantly lower post-listing annual compliance costs should be a central message in any listing pitch.

    Source: https://www.securities-administrators.ca/news/canadian-securities-regulators-announce-adoption-of-semi-annual-financial-reporting-pilot/

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