Six Years In The Making: How Can Canadian Reporting Issuers Finally Use The CSA’s New Access Model For Financial Statements And MD&A?

On June 25, 2026, the Canadian Securities Administrators (“CSA”) published final amendments to National Instrument 51-102 Continuous Disclosure Obligations and National Instrument 54-101 Communication with Beneficial Owners of Securities of a Reporting Issuer, together with related companion policy changes.¹

The changes introduce a new “access model” for certain continuous disclosure documents of reporting issuers other than investment funds. Subject to the necessary ministerial approvals, the amendments come into force on September 22, 2026.²

The concept is straightforward. A reporting issuer that adopts the access model may satisfy applicable securities law delivery requirements for annual financial statements, interim financial reports, and the related management’s discussion and analysis (“MD&A”) (collectively, the “CD documents”) by providing electronic access to them instead of following the existing physical delivery requirements.³

The model is entirely voluntary. Issuers may adopt it for annual filings only, for interim filings only, or for both, and those that do are relieved of the annual request form and default delivery obligations for the applicable documents.

What Is the CSA Access Model and When Was It Introduced?

The CSA first floated the concept in a January 2020 consultation paper, and in April 2022 published proposed access model rules covering both prospectuses and CD documents.⁴

The prospectus piece moved faster: an access model for prospectuses came into force in April 2024.⁵ The CD document piece required a second round of consultation, republished in November 2024 with revisions aimed at investor protection concerns, particularly the potential impact on retail investors.⁶

The June 2026 publication finalizes that work. CSA Chair, Stan Magidson, framed the change as a recognition that “investors are increasingly accessing and consuming information electronically.”⁷

How Does the CSA Access Model Work for Financial Statements and MD&A?

Adoption begins with notice. An issuer moving to the access model must issue and file a news release on SEDAR+ at least 25 calendar days before relying on the model for the first time.⁸ That release must tell investors that the issuer is adopting the model, that SEDAR+ now offers a notification function allowing anyone to subscribe for email alerts when the issuer files its CD documents, how copies of the documents can be obtained, and that standing instructions may be provided.⁹ A single release can cover both annual and interim documents.

Notably, the advance notice applies only on the way in; no corresponding notice is required if an issuer later returns to conventional delivery.¹⁰

What Are the Ongoing Requirements Under the CSA Access Model?

Once the model is in place, each filing must follow three steps:¹¹

• File on SEDAR+. The CD document must be filed on SEDAR+ as usual.
• News release within one calendar day. The issuer must issue and file a news release whose title expressly references the availability of the document on SEDAR+ and states that:
  1. the document is accessible electronically through SEDAR+,
  2. the notification function is available,
  3. an electronic or paper copy may be requested at no charge, and
  4. any standing instructions will continue to be honoured.

This disclosure can be folded into a broader release, such as the quarterly earnings release, provided the title and content requirements are met.

• Website posting within two calendar days. An issuer that maintains a website must post the document itself, or a hyperlink leading directly to it on SEDAR+ within two calendar days of filing. The CSA’s companion policy provides that the document should remain accessible until the corresponding documents for the following financial period have been filed and posted.

In addition, in each year that an issuer relies on the model, prescribed access disclosure must appear in a prominent location in its proxy-related materials, in the notice delivered under the notice-and-access regime, or in a separate document sent alongside either.¹² Where the issuer maintains a website, the same disclosure must also be posted in the same location as the CD documents.¹³

What Delivery Requirements Remain Unchanged Under the CSA Access Model?

Investor entitlements are preserved under the access model. For example, securityholders, other than holders of debt instruments, retain the right to request an electronic or paper copy of any CD document at no charge, and the issuer must send it within the prescribed timeframe.¹⁴ Standing instructions that beneficial owners have given their intermediaries remain fully operative, regardless of whether the issuer has adopted the model.¹⁵

The model is also deliberately narrow. Critically, it applies only to financial statements and MD&A. Proxy-related materials, takeover bid circulars, and issuer bid circulars remain subject to existing delivery requirements.¹⁶

Notably, the model addresses securities law delivery requirements only. Thus, delivery obligations under an issuer’s governing corporate statute, such as the requirement to place annual financial statements before shareholders, are not displaced and must be satisfied independently.

What Should Reporting Issuers Do Before September 22, 2026?

The savings here are real and the compliance burden is modest, but the timelines are firm and the details are prescriptive. Issuers intending to rely on the access model for their next interim or annual filings should begin preparations by:

• Mapping the 25-day advance notice against their upcoming filing calendars.
• Updating disclosure controls and compliance calendars to capture the one-day news release and two-day website posting deadlines.
• Confirming that their website processes can meet the required timeline.
• Building the annual access disclosure into next season’s proxy preparation.
• Keeping copy requests and standing instruction processes fully intact.

Footnotes

1 Canadian Securities Administrators, CSA Notice of Amendments and Changes to Implement an Access Model for Certain Continuous Disclosure Documents of Non-Investment Fund Reporting Issuers (25 June 2026) [“CSA Notice”] at 1.

2 Ibid at 1.

3 Ibid at 2.

4 Ibid.

5 Ibid.

6 Ibid at 3.

7 Ibid at 2.

8 National Instrument 51-102 Continuous Disclosure Obligations, ss. 4.5.1(2)-4.5.2(2), as amended effective 22 September 2026 [“NI 51-102”]; Companion Policy 51-102CP Continuous Disclosure Obligations, s.3.3.2(1), as amended effective 22 September 2026 [“Companion Policy 51-102CP”].

9 NI 51-102, supra note 4 at s. 4.5.1(2)(b)

10 CSA Notice, supra note 1 at 4.

11 Ibid at 2.

12 NI 51-102, supra note 4 at s.4.5.3(2)(a)-(c); Companion Policy 51-102CP, supra note 4 at s.3.3.1(3).

13 NI 51-102, supra note 4 at s.4.5.4(b); Companion Policy 51-102CP, supra note 4 at s.3.3.1(7).

14 Companion Policy 51-102CP, supra note 4 at s.3.3.1(1).

15 Ibid at s.3.3.1(5); CSA Notice, supra note 1 at 2.

16 CSA Notice, supra note 1 at 14.