Canadian Securities Administrators Adopt Semi-Annual Reporting Pilot Project

On March 19, 2026, the Canadian Securities Administrators (CSA) announced the adoption of a pilot project (the “SAR Pilot”) that permits eligible venture issuers to voluntarily report on a semi-annual basis. The SAR Pilot, implemented through Coordinated Blanket Order 51-933 – Exemption to Permit Semi-Annual Reporting for Certain Venture Issuers (the “Blanket Order”), exempts eligible venture issuers listed on the TSX Venture Exchange (TSXV) or the Canadian Securities Exchange (CSE) from the requirement to file first- and third-quarter financial reports under National Instrument 51-102 – Continuous Disclosure Obligations. The SAR Pilot represents a significant step in the CSA’s ongoing efforts to reduce the regulatory burden on smaller public companies while maintaining adequate investor protection.

Eligibility

To be eligible for the SAR Pilot, issuers must meet the following criteria:

• be listed on the TSXV or the CSE;
• have annual revenue of no more than $10 million, based on the issuer’s most recently completed fiscal year;
• have at least a 12-month continuous disclosure record;
• have filed all periodic and timely continuous disclosure documents required to be filed under applicable Canadian securities laws; and
• have not been the subject of any penalties, sanctions, or cease trade orders within the last 12 months.

These eligibility requirements must be satisfied at the end of each quarter for which the issuer intends to participate in the SAR Pilot, making eligibility an ongoing assessment. If an eligible issuer chooses to participate in the SAR Pilot, they must issue and file a news release on SEDAR+ announcing their adoption of semi-annual reporting. Notably, the SAR Pilot does not alter the financial statement disclosure requirements for prospectus offerings, and issuers participating in the SAR Pilot will not be exempt from the quarterly financial statement disclosure requirements for a prospectus. Issuers participating in the SAR Pilot that file a base shelf prospectus must cease participation in the SAR Pilot.

Looking Forward

While the Blanket Order is in effect, the CSA intend to engage in a broader rule-making initiative regarding voluntary semi-annual financial reporting and will use insights gained from the SAR Pilot to inform that process. We support implementation of the SAR Pilot and encourage the CSA to closely monitor its impact on our capital markets to assess whether voluntary semi-annual reporting should be made more broadly available to our reporting issuers.

For further information, please contact any member of our Capital Markets Group.