Canadian Securities Administrators Propose Semi-Annual Reporting Pilot Project

On October 23, 2025, the Canadian Securities Administrators (CSA) announced a pilot project to allow certain venture issuers to voluntarily adopt semi-annual financial reporting (the “SAR Pilot”). The SAR Pilot will be implemented as a coordinated blanket order across the CSA and exempts qualified issuers listed on the TSX Venture Exchange (TSXV) or the CNSX Markets Inc. (CSE) from the requirement to file first and third quarter financial reports under National Instrument 51-102 Continuous Disclosure Obligations.

The SAR Pilot is subject to a 60-day comment period, which expires on December 22, 2025.

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;
• 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.

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 electing to file on a semi-annual basis will not be exempt from the quarterly financial statement disclosure requirements for a prospectus. The SAR Pilot is a multi-year pilot project and does not have an expiry date, except in Ontario where the blanket order will include an 18-month expiry date (as required under Ontario law).

Looking Forward

The CSA intends to use knowledge gained from the SAR Pilot to inform a broader rule-making project related to voluntary semi-annual reporting.

We encourage interested parties to seek our assistance in providing input or preparing a submission to the CSA on the SAR Pilot or other initiatives intended to revitalize Canada’s capital markets.

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