On November 21, 2024, the Canadian Securities Administrators (CSA) published a notice and request for comment on their proposed amendments to Multi-lateral Instrument 13-102: System Fees (MI 13-102). 

This notice proposes an increase to SEDAR+ system fees over five years, which is required to better align system fee revenues with projected national operating costs.  

In 2019, CSA proposed simplifying the system fee structure, as well as removing system fees for certain filing types and introducing some new fees. The resulting amendments to MI 13-102 were implemented when SEDAR+ went live in July 2023.

The CSA states that under this new structure, the system fee changes combined with changes in filing patterns reduced the annual fee revenue by 18% in fiscal 2024. 

While revenue decreased, the CSA experienced higher labour costs for IT services, with increases between 35% and 45% from 2021 to 2024 due to factors including higher technology expenses and greater need for cybersecurity risk mitigation. CSA expects these costs will continue to rise over the next few years. 

Proposed system fee increases

To address increasing operating costs, CSA is proposing the following system fee increase over the next five years: 

  • A 60% system fee increase in November 2025
  • A 3% system fee increase in each of the following four years

How will these changes affect you?

CSA states this increase will be less than $2,500 for 95% of filing and registrant organizations and less than $1,000 for 85% of filing and registrant organizations in the first year.

In the meantime, CSA is reviewing ways to improve operating efficiencies for national systems and is developing a long-term strategic plan including the use of the latest technology tools and alternative operating methods. 

You can read the full CSA notice and request for comment which includes a chart detailing system fees. 

Computershare is not providing, and does not intend to provide, any legal, tax or investment advice.

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