CIRO Proposes New Guidance to Support DIY Investors

By: Michael Holder, Kanchan Mehta, Rijja Baig

The Proposal in Brief

The Canadian Investment Regulatory Organization (“CIRO”) is proposing new guidance to replace CIRO Guidance Note 3400-21-003 to allow Order Execution Only (“OEO”) dealers to offer more educational tools to do-it-yourself (“DIY”) investors. These tools can include alerts, sample portfolios, and self-assessment resources. The goal is to help investors make informed decisions without crossing into personalized investment advice.

CIRO says it will ensure safeguards are in place, including transparency on how tools should be used, monitoring for conflicts of interest and keeping materials up to date. CIRO’s focus is to balance innovation in the OEO channel with strong investor protection.

Why It’s Necessary

Today, many DIY investors rely on social media, online forums, and “finfluencers” for financial information - sources that are often unregulated and unreliable. CIRO’s own research found that investors want more tools and safeguards from their DIY investing platforms. However, existing rules have limited OEO dealers from sharing decision-making supports because of concerns that such information might be seen as advice without the benefit of KYC information. The proposed changes clarify that OEO firms can share educational and informational resources if they do not recommend specific investments.

The urgency of this reform is underscored by the recent Alberta Securities Commission decision in Re Floreani (2025 ABASC 41), where enforcement action against a financial influencer highlighted the risks retail investors face when relying on unregulated online advice. By widening what OEO dealers can provide, CIRO aims to reduce the risk of investors acting on misleading or incomplete online information. The move reflects a growing consensus that current restrictions hold back useful, regulated content that could help protect investors.

It is encouraging that with this proposed re-think of the account services and activities available to DIY investors, as well as the thoughtful questions for which CIRO is also requesting feedback, CIRO has clearly demonstrated its ability to listen to and learn from varied industry input, and to put DIY clients’ interests first in its own rulemaking process. 

Next Steps

The proposal will be finalized in 2026 after industry and stakeholder input. Comments, as well as responses to the specific questions, are due by November 10. If you would like assistance with submitting a comment letter, North Star Legal's team has helped create several novel products for OEO firms and are available to help leverage that expertise for your submission or create services that your OEO clients need.