CIRO advances phase 2 of its UMIR Guidance Update Project

The guidance clarifies trading rules expectations without imposing additional obligations.

The second phase of a multistage effort to consolidate and modernize its trading rules guidance without altering the substance of the rules themselves has been started by the Canadian Investment Regulatory Organization (CIRO).

Launched earlier this year, Universal Market Integrity Rules (UMIR) Guidance Update Project intends to make CIRO’s guidance notes easier to navigate and eliminate outdated or duplicative material that has accumulated through years of rulemaking.

Phase 1, which was completed in August, involved the withdrawal of obsolete guidance, and minor editorial revisions to improve accuracy and consistency. It set the groundwork for the more substantial updates now appearing in Phase 2, which CIRO described as a continuation of its effort to simplify interpretation for dealers and compliance staff.

The first publications under Phase 2 include revised notes on “double printing,” trading in securities denominated in different currencies, and the application of trading rule obligations to “access persons.” 

The following was covered:

  • The updated double printing guidance clarified that when two trades are executed where one would have sufficed, the resulting appearance of extra volume may create a false or misleading impression of market activity. (GN-URPART2-25-0002.)
  • A note on securities that trade in both Canadian and US dollars specified that these should generally be viewed as separate securities for the purposes of best-bid, best-ask, and last-sale calculations, though trading in both currencies may be aggregated when determining whether a security is “highly liquid.” (GN-URPART7-25-0004.)
  • A third clarification confirms that manipulative and deceptive trading provisions apply equally to access persons, for example individuals with direct market connectivity who are not registered participants. (GN-URPART1-25-0002.)

CIRO has emphasized that the guidance update project does not change rule obligations or create new ones. Instead, the updates are designed to improve coherence and reduce interpretive uncertainty that can complicate firms’ supervisory and compliance processes. 

CIRO expects to publish additional revised notes intermittently throughout the rest of the 2026 fiscal year.