PMAC acknowledges the work the CSA is doing to reduce regulatory burden and increase competition in Canada’s capital markets, especially given the current economic uncertainty. Providing blanket exemptions from certain continuous disclosure requirements and establishing the voluntary semi-annual reporting framework may contribute to reducing regulatory burden for the relevant issuers. There may also be a benefit to harmonizing these requirements to semi-annual reporting rules in other international jurisdictions.
However, we are concerned that there are risks associated with providing less disclosure to investors, which may make the changes less impactful, and result in unintended consequences. Although we support the pilot project as such, we also agree with the concerns set out by the Canadian Coalition for Good Governance (CCGG) in its submission dated December 2, 2025, and therefore urge the CSA to proceed with caution.
KEY RECOMMENDATION
Proceed with the pilot project as described, and carefully analyze any resulting impact on issuers, investors and the capital markets before making permanent changes or expanding the changes to other categories of issuers.
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