I want to sell exempt-market products. Should I write CSC or CIRE?

CSC. The CIRE is for CIRO registration. Exempt market dealer registration is under the CSA via NI 31-103, and the CSA still accepts the CSC for EMD reps. Confirm with your principal regulator (e.g., OSC if Ontario-based) before paying for any prep, since some jurisdictions also accept the EMPE.

Why didn't the CSC get retired for EMDs at the same time?

Different regulator. The CSC retirement was a CIRO decision under the CIRO Proficiency Model rollout. CIRO has authority over investment dealers and mutual fund dealers but not over exempt market dealers, which are CSA-regulated. The CSA chose not to retire the CSC for the registration categories under its direct purview.

What's the EMPE and how does it relate to the CSC?

The Exempt Market Products Exam is a focused alternative to the CSC for EMD-only candidates. It covers the same regulatory and product material as the CSC but with deeper depth on exempt-market specifics. Under NI 31-103 §3.10, either is generally accepted for EMD reps. The CSC has broader downstream value if the candidate may move into CIRO-regulated work later.

If I have CSC but want to add CIRO registration later, do I need CIRE?

Yes. The CSC does not waive the CIRE for CIRO registration. If you start in EMD work and later move to a CIRO investment dealer, you write the CIRE plus the matching CIRO exam (Retail Securities, Supervisor, Trader, etc.). Your CSC pass remains valid for any continued EMD or CSA-only work.

Where do I confirm EMD proficiency rules for my province?

Each CSA member jurisdiction has its own registrant compliance group. Start with the principal regulator in the jurisdiction where the EMD's head office sits: OSC (Ontario), AMF (Quebec), BCSC (BC), ASC (Alberta). NI 31-103 is harmonized across the CSA, but transitional guidance can vary by province.

CSC for Exempt Market Dealer (EMD) Reps in 2026

When CIRO retired the CSC on January 1, 2026, the retirement applied only to CIRO-registered representatives. Exempt Market Dealer (EMD) representatives are registered under NI 31-103 directly with the CSA (provincial regulators), not under CIRO. CSI continues to offer the CSC for EMD candidates, and the CSA continues to accept it as the foundational proficiency credential under §3.10 of NI 31-103. If your target role is dealing in exempt-market securities (prospectus-exempt offerings, private placements, MICs, hedge funds, exempt-market investment funds), the CSC is still on your path.

The CSC's Enduring Role for Exempt Market Dealers

The Canadian Securities Course (CSC) remains a recognized proficiency credential for Exempt Market Dealer (EMD) registration in Canada. This continued acceptance is because EMDs operate under the direct regulation of the Canadian Securities Administrators (CSA), which are provincial and territorial regulators. The CSC's retirement on January 1, 2026, was a decision made by CIRO and specifically applied to individuals seeking registration with CIRO-regulated firms.

For EMD representatives, the foundational proficiency requirement is established under National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (NI 31-103). The CSA continues to accept the CSC as meeting this standard. If your career path involves dealing in exempt-market securities, such as prospectus-exempt offerings or private placements, the CSC is still a relevant and accepted qualification.

Understanding the Regulatory Divide: CIRO vs. CSA

The Canadian financial industry operates under distinct regulatory authorities, which is key to understanding the CSC's ongoing relevance for EMDs. CIRO (Canadian Investment Regulatory Organization) oversees investment dealers and mutual fund dealers. Its recent proficiency model changes, including the retirement of the CSC for its registrants, were specific to firms under its jurisdiction.

In contrast, Exempt Market Dealers are regulated directly by the provincial and territorial securities commissions that comprise the CSA. This includes regulators like the Ontario Securities Commission (OSC) and the British Columbia Securities Commission (BCSC). The CSA maintains its own set of proficiency standards for EMDs under NI 31-103. CIRO has no jurisdiction over EMD representatives or the firms they work for. Therefore, CIRO's decisions regarding proficiency requirements do not impact the registration categories under the CSA's direct purview.

Proficiency Requirements for Exempt Market Dealer Representatives

The specific proficiency requirements for Exempt Market Dealer representatives are outlined in National Instrument 31-103. This instrument details the educational qualifications and experience necessary for registration. Under NI 31-103 §3.10, the Canadian Securities Course (CSC) is explicitly listed as one of the recognized credentials that satisfies the foundational proficiency requirement for EMD representatives.

The Canadian Securities Institute (CSI) continues to offer the CSC specifically for candidates pursuing EMD registration and other CSA-registered categories. Meeting these specific regulatory requirements is mandatory for anyone seeking to register as an EMD representative. The CSA's acceptance of the CSC ensures a clear and established path for individuals entering this sector of the financial market.

The Exempt Market Products Exam (EMPE) as an Alternative

Beyond the CSC, the Exempt Market Products Exam (EMPE) is another accepted proficiency option for individuals seeking EMD registration. The EMPE is a more focused examination compared to the broader CSC. It covers the regulatory framework and product knowledge relevant to the exempt market with greater depth on specific exempt-market offerings.

Under NI 31-103 §3.10, both the CSC and the EMPE are generally accepted for EMD representatives. Candidates should verify EMPE acceptance with their principal CSA regulator, such as the Autorité des marchés financiers (AMF) in Quebec, as specific jurisdictional guidance can vary. While the EMPE is tailored, the CSC offers broader utility. Passing the CSC can provide a more versatile foundation if a candidate anticipates potentially moving into CIRO-regulated work later in their career.

What Exempt Market Dealers Sell and How

Exempt Market Dealers specialize in facilitating investments in products that are sold under prospectus exemptions. These products are not publicly traded on stock exchanges and are typically offered to specific types of investors. Common product types include hedge funds, Mortgage Investment Corporations (MICs), private Real Estate Investment Trusts (REITs), and oil and gas Limited Partnerships.

These offerings are governed by National Instrument 45-106 Prospectus Exemptions (NI 45-106), which outlines the conditions under which securities can be sold without a full prospectus. Examples of common prospectus exemptions include the accredited investor exemption, which allows sales to individuals or institutions meeting specific financial thresholds, and the $150,000 minimum investment exemption for certain non-individual investors. Understanding NI 45-106 is critical for EMDs, as it defines the legal framework for their business activities.

Transitioning Between EMD and CIRO Roles

Candidates who begin their careers as Exempt Market Dealer representatives and later consider transitioning to a CIRO-registered role need to understand the distinct proficiency requirements. The CSC, while valid for EMD registration, does not waive the Canadian Investment Regulatory Organization Exam (CIRE) for CIRO registration. The CIRE replaced the CSC as the foundational exam for CIRO registrants as of January 1, 2026.

If an EMD representative moves to a CIRO investment dealer, they will typically need to write the CIRE. In addition to the CIRE, they must also complete a relevant role-specific CIRO exam, such as the Retail Securities Exam or the Supervisor Exam. It is important to remember that your CSC pass remains valid for any continued EMD or other CSA-only work, but it does not fulfill the new CIRO proficiency requirements.

Verifying Provincial EMD Requirements

While National Instrument 31-103 provides a harmonized framework across Canada, candidates should always confirm specific EMD proficiency rules with their provincial principal regulator. Each CSA member jurisdiction has its own registrant compliance group that can provide definitive guidance.

For example, candidates in Ontario should contact the Ontario Securities Commission (OSC). Those in Quebec would reach out to the Autorité des marchés financiers (AMF). In British Columbia, the British Columbia Securities Commission (BCSC) is the relevant authority, and in Alberta, it's the Alberta Securities Commission (ASC). Although NI 31-103 is largely consistent, transitional guidance, specific interpretations, or additional local requirements can vary by province. Direct contact with the principal regulator in the EMD's head office jurisdiction ensures accurate information for registration.

Mini-Quiz: Test Your Knowledge

Which regulator oversees Exempt Market Dealers? a) CIRO b) CSA c) IIROC d) MFDA
What National Instrument primarily governs EMD registration requirements? a) NI 81-102 b) NI 45-106 c) NI 31-103 d) NI 24-101
When did the CSC retirement for CIRO-registered representatives take effect? a) January 1, 2025 b) January 1, 2026 c) July 1, 2025 d) July 1, 2026
Which exam is a focused alternative to the CSC for EMD-only candidates? a) CIRE b) CPH c) EMPE d) OLC
If an EMD rep with a CSC wants to become a CIRO-registered investment dealer, what is typically required? a) Only the CSC is sufficient. b) Only the CIRE is sufficient. c) The CIRE plus a role-specific CIRO exam. d) Neither the CSC nor CIRE is needed.

Answers: 1. b, 2. c, 3. b, 4. c, 5. c

Frequently Asked Questions

I want to sell exempt-market products. Should I write CSC or CIRE? CSC, as EMDs are CSA-regulated under NI 31-103, not CIRO.
Why didn't the CSC get retired for EMDs at the same time? Different regulators; CIRO's decision only applied to CIRO-regulated categories, not CSA-regulated EMDs.
What's the EMPE and how does it relate to the CSC? The Exempt Market Products Exam is a focused alternative to the CSC for EMDs, generally accepted under NI 31-103 §3.10.
If I have CSC but want to add CIRO registration later, do I need CIRE? Yes, the CSC does not waive the CIRE for CIRO registration; you would need the CIRE plus a role-specific CIRO exam.
Where do I confirm EMD proficiency rules for my province? Contact the principal regulator in the EMD's head office jurisdiction (e.g., OSC, AMF, BCSC, ASC).

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