The Canadian Investment Regulatory Organization (CIRO) has published its Proposed Crypto Trading Platform Regulation Fee Model (the Proposed Crypto Fee Model) for review and comment for a period ending September 28, 2026.
CIRO intends to implement the Proposed Crypto Fee Model, July 1, 2027, in accordance with the CSA Recognition Orders to recover crypto trading platform surveillance costs using an activity-based cost allocation methodology. From July1, 2027, to March 31, 2028, cost recovery will be based on direct costs only. Beginning April 1, 2028, CIRO will transition to full cost recovery as the majority of CIRO members are expected to be registered by that time.
Under the Proposed Crypto Fee Model, costs will be allocated using a two-step process. Total surveillance costs are first distributed across levels based on relative supervisory effort and
then further allocated to individual members based on their trading activity. The model has three levels, on which members will be placed, based on their individual surveillance requirements.
All members would be subject to an annual minimum fee, ranging from $50,000to $100,000 depending on their level, with transitional relief available for certain new level 1 members.
The Proposed Crypto Trading Platform Regulation Fee Model is available for download from the websites of the Canadian Investment Regulatory Organization.
For more information, please call Barbara Hendrickson at BAX Securities Law (647) 403-4606.
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