Five Years, Two Regulators: Comparing the CSA's Year in Review Reports and the OSC's Statements of Priorities
Every August, the Canadian Securities Administrators (CSA) publish a Year in Review, a retrospective accounting of the pan-Canadian regulatory work undertaken over the preceding twelve months. Every autumn, the Ontario Securities Commission (OSC) publishes a Statement of Priorities (SoP), a forward-looking articulation of what it intends to do in the year ahead. Read individually, each document is a useful but narrow snapshot. Read together, across five consecutive cycles, they form something more valuable: a record of when Canada's largest capital markets regulator and its largest provincial member have moved in tandem, when one regulator’s initiatives may reveal upcoming policy shifts, and where there is dissonance.
This article traces that record across the five most recent CSA reporting cycles: the CSA's Year in Review reports and the OSC's corresponding Statements of Priorities. The goal is to identify the through-lines: where the CSA and OSC have moved together, where the OSC has led the pan-Canadian consensus, where other jurisdictions are leading, and what legal and compliance teams should be watching as both bodies enter a new planning cycle.
Part One: The Arc of the CSA Year in Review
From six goals to four: a narrower, sharper mandate
When compared side by side structurally significant changes to the CSA’s reports over the five-year period is evident. The 2022–2025 Business Plan organized activity around six overlapping strategic goals. The 2025–2028 Business Plan, first reflected in the 2025–2026 Year in Review, uses four: capital markets, investors, innovation and technology, and systemic risk. It has narrowed toward competitiveness and capital formation, with investor protection and systemic risk kept as distinct pillars.
Self-regulatory consolidation: from launch to routine oversight
CIRO's creation dominates the early years, beginning with the amalgamation of IIROC and the MFDA and the merger of the two investor protection funds. The narrative shifts to oversight mechanics, including rulebook harmonization, an oversight review, a compliance sweep on Client Focused Reforms, then to delegation of registration functions to CIRO, which is steadily absorbing functions CSA members once performed directly as the CSA repositions toward oversight and adjudication.
Enforcement: rising volume, then a pivot to disruption-at-scale
The enforcement appendices tell a quantitative story, as investor alerts and warnings climbed steadily from 758 in 2022–2023 to 1,011 in 2024–2025, before falling to 763 in 2025–2026. That decline coincided with a December 2025 initiative that disabled more than 11,700 fraudulent platforms within a year. The CSA appears to have substituted technological disruption for reactive public warnings against the highest-volume category of fraud. Crypto-related matters now dominate enforcement, accounting for over 85% of alerts, up from roughly half three years earlier.
Some enforcement metrics have been comparatively flat, including proceedings commenced and fines and penalties. Restitution and disgorgement orders, by contrast, have grown sharply, from $20.9 million in 2022–2023 to $110.7 million in 2024–2025, driven largely by a handful of large fraud cases.
Crypto assets: from containment to structured integration
No theme evolved more visibly across the five years than crypto regulation, whose posture has moved from contain and enforce, to register and supervise, to anticipate the next wave of digitization.
The 2022–2023 report was preoccupied with establishing control: enhanced pre-registration undertakings after major crypto-platform insolvencies, restrictions on leverage and stablecoin trading, and enforcement against unregistered platforms. Subsequent years brought structured onboarding, including proposed rules for funds holding crypto assets and an interim stablecoin framework, culminating in a deadline for platforms to obtain CIRO membership as investment dealers.
The 2025–2026 report reflects further maturation: the CSA now monitors prediction markets and stablecoins as adjacent risk categories, in addition to examining how tokenized assets intersect with securities law.
ESG and diversity disclosure: proposed, then paused
The climate- and diversity-related disclosure files illustrate a genuine reversal. Proposed rules dating to October 2021 were still being refined as late as 2023–2024, but ESG has since been shelved in favour of voluntary disclosure aligned with CSSB/ISSB standards. ESG is a good example of Canadian regulation reshaped by foreign developments to preserve competitiveness.
Burden reduction and competitiveness: the dominant late-period theme
If the early years were defined by SRO consolidation and crypto containment, recent years have been defined by a pivot toward capital-raising competitiveness, such as a permanent shelf regime, an access-equals-delivery model for continuous disclosure, voluntary semi-annual reporting for venture issuers, and a harmonized prospectus exemption. Capital raised under the listed issuer financing exemption grew nearly eightfold after its May 2025 limit increase, with issuers raising almost $4 billion in the first year alone. The 2025–2026 report frames Consultation Paper 51-406 as the next phase, covering private placement hold periods, financial reporting reform, and material change reporting.
Still missing from this focus on capital raising is the long-overdue harmonization of National Instrument 45-106. Canada's current trade situation provides governments and their regulators the opportunity to facilitate private capital raising.
Unfinished business: OBSI's binding authority
The initiative to provide the Ombudsman for Banking Services and Investments binding decision-making authority was a consistent item in all the reports.
Part Two: Where the CSA and OSC Converge — and Where They Don't
Placing the two-document series side by side across five years surfaces three patterns.
First, near-total convergence on the big structural files. CIRO's creation and subsequent functional delegation, OBSI's push for binding authority, and the pivot from ESG rulemaking to voluntary disclosure all appear in essentially the same sequence and with essentially the same timing in both the CSA and OSC documents. These events provide a useful confirmation for compliance teams that these files genuinely are being driven at the pan-Canadian level. The OSC's SoP language is typically anticipating, by three to twelve months, initiatives that later appear as completed or in-progress items in the CSA's Year in Review.
Second, a shared pivot to competitiveness. Both the CSA and OSC reorganized their strategic frameworks in the same rough window. Both reorganizations had the effect of elevating capital formation and burden reduction from a subordinate theme to a headline strategic goal. The OSC arrived at this destination roughly a year before the CSA's business-plan-level reorganization caught up, though CSA-level burden-reduction initiatives (such as the LIFE exemption expansion and semi-annual reporting) were already well underway before the CSA's 2025–2028 framework formalized competitiveness as a distinct goal.
Third, genuinely OSC-specific initiatives sit alongside the shared CSA agenda. OSC TestLab, the OSC's regulatory sandbox and testing initiative, is an Ontario-specific vehicle while the CSA's Collaboratory serves an overlapping, pan-Canadian testing function.
Part Three: Practical consequences for Compliance and Legal Teams
Several practical implications follow from this five-year comparison:
Track the CSA's "Looking Ahead" sections as a leading indicator. Across all the reports in the review window, initiatives flagged in one year's "Looking Ahead" section reliably surfaced as substantive rulemaking within twelve to eighteen months. The 2025–2026 report's reference to CSA Consultation Paper 51-406 is the most immediate example, so industry should expect further activity on private placement hold periods, alternative financial reporting for venture issuers, and material change reporting through 2026–2027.
Anticipate finalization, not further delay, on the principal distributor and chargeback files. Both moved from proposal (2024) to near-final amendment (mid-2026) within roughly two years, suggesting genuine momentum toward implementation.
Watch the early warning/take-over bid and MI 61-101 reviews, which have appeared as active priorities consistently since 2023 without yet reaching final rule stage. These initiatives could be the next major structural reforms to reach the finish line given their persistence across five consecutive planning cycles.
Expect continued CIRO delegation. Both the CSA and OSC frame Phase 1 registration delegation to CIRO as a first step. Phase 2 delegation of additional registration functions is under consideration in the OSC's most recent Statement of Priorities and should be monitored closely by dually registered firms.
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Next Steps with North Star Group
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About the Authors
Michael Holder (B.A. Western, LL.B. Windsor, MBA, Western) is the Managing Partner of North Star Legal, bringing more than 20 years of wealth management, legal, and compliance experience in Canada's largest law firms, financial institutions, securities regulators and financial technology companies. Michael acted as Associate General Counsel and Chief Compliance Officer of Wealthsimple, Senior Legal Counsel at BMO Financial Group, and a partner of one of Canada's largest firms. He has previously taught Securities Law at Windsor Law School, as well as Fintech and Disruption of Banking at Ivey Business School.
Read Michael’s full bio here.
Martha Rafuse (B.A. Western, LL.B. Osgoode, LL.M London School of Economics), is a Partner at North Star Legal, bringing more than two decades of securities regulatory experience across the financial industry, private legal practice, and government. Before joining North Star Legal, Martha led large compliance teams for both Canadian and U.S. firms, including RBC Phillips, Hager & North Investment Counsel Inc., RBC Dominion Securities Inc. (Retail), and RBC Royal Mutual Funds. At the Ontario Securities Commission, she developed novel legal solutions and led significant policy initiatives involving NI31-103.
Read Martha’s full bio here.