CSA finalizes new access model for electronic delivery of financial disclosure

On June 25, 2026, the Canadian Securities Administrators (CSA) announced final amendments to National Instrument 51-102 Continuous Disclosure Obligations, National Instrument 54-101 Communication with Beneficial Owners of Securities of a Reporting Issuer, and corresponding companion policy revisions, to adopt a new access model for certain continuous disclosure documents of non-investment fund reporting issuers (the Amendments).

The Amendments follow the CSA’s implementation of a similar access model for prospectuses, which came into force in April 2024.

Pending regulatory approval, the Amendments will become effective on September 22, 2026.

Requirements for reporting issuers who want to use the access model

Under the voluntary access model, reporting issuers may meet their regulatory obligations to deliver financial disclosure to investors by making annual financial statements, interim financial reports, and related management's discussion and analysis (MD&A) available via electronic access rather than mailing paper copies.

Reporting issuers may adopt the access model for annual financial statements and related MD&A, interim financial reports, and related MD&A, or both. They are not required to adopt it for all document types at once. Where the access model is used for only one category, the existing delivery requirements continue to apply to the other.

To rely on the access model, a reporting issuer must:

• file the applicable continuous disclosure documents on SEDAR+ (as all reporting issuers are required to do regardless of whether they rely on the access model);
  
  
• issue and file a news release on SEDAR+ no later than one calendar day after filing, with a title referencing the availability of the documents on SEDAR+. The news release must also state that the documents are accessible on SEDAR+ and, where applicable, on the reporting issuer’s website, that the SEDAR+ notification functionality is available, that an electronic or paper copy of the document can be obtained upon request, and that any standing delivery instructions will continue to be followed; and
  
  
• if the reporting issuer maintains a website, post either the documents themselves or a direct hyperlink to the SEDAR+ filing within two calendar days after filing.

The access model does not require a standalone news release. Reporting issuers may combine the required disclosure with other information in a news release (for example, in an earnings news release).

Reporting issuers that elect to use the access model are relieved of the obligation to annually send a request form or copies of financial statements and MD&A to securityholders. Those documents will instead be accessible electronically through SEDAR+ and the reporting issuer’s website.

Reporting issuers using the access model must also provide ongoing disclosure explaining how investors can access financial disclosure documents, subscribe to SEDAR+ notifications, and confirm that any existing delivery preferences for electronic or mailed copies will continue to be respected. This disclosure must be provided annually through proxy-related materials, notice-and-access materials or accompanying communications, and must also be posted on the reporting issuer's website where applicable.

A reporting issuer may continue to use existing delivery methods if it chooses.

Investor protection measures

While the Amendments are expected to lower printing and mailing expenses and improve the efficiency of communications with securityholders, the CSA highlighted the importance of preserving investor access. Investors will continue to have the right to request electronic or paper copies of financial statements and MD&A, and any existing delivery preferences will remain in effect. If a securityholder requests a copy of a document, the reporting issuer must send it at no charge.

The CSA also highlighted SEDAR+'s notification functionality, which allows investors to subscribe to email notifications when continuous disclosure documents are filed and access the relevant documents through embedded links.

Practical considerations for reporting issuers

For many reporting issuers, the access model will meaningfully reduce printing and mailing costs. However, it is not a simple opt-in: adoption introduces new operational requirements with prescribed deadlines for news releases and website postings. Reporting issuers considering whether to adopt the model should assess its suitability for their investor base and begin preparation in advance. The access model is voluntary and may not suit each reporting issuer’s circumstances.

Reporting issuers intending to rely on the access model for the first time should focus on the following implementation steps:

• Confirm eligibility and scope. Determine whether to adopt the model for annual financial statements, interim financial reports, or both. Reporting issuers that were using the traditional delivery or request-form process during the previous financial period must issue and file a news release at least 25 calendar days before initial use. A reporting issuer adopting the model for both annual and interim documents may combine the required advance news releases into a single release. Conversely, a reporting issuer that decides to stop using the access model may simply revert to traditional delivery without issuing a separate exit notice.
  
  
• Review news release and website processes. Reporting issuers will need to issue and file a news release within one calendar day of each SEDAR+ filing and, if they maintain a website, post the documents or a direct SEDAR+ hyperlink within two calendar days. Internal workflows and any third-party service providers should be updated to meet these deadlines consistently.
  
  
• Update proxy materials and website disclosures. The access model requires annual disclosure to investors explaining how to electronically access documents, subscribe to SEDAR+ notifications, request copies, and confirm standing instructions. This disclosure must appear in proxy-related materials, notice-and-access materials, or an accompanying communication, and on the reporting issuer’s website.
  
  
• Assess corporate law and other delivery obligations. The access model applies only to delivery requirements under Canadian securities laws. Reporting issuers should confirm whether separate obligations under corporate statutes (for example, the financial statement delivery requirements under the Canada Business Corporations Act), organizational documents, or other applicable requirements continue to require delivery of financial disclosure.
  
  
• Consider investor base. Reporting issuers should also consider how changes in delivery practices may be received by their investor base, and whether supplementary communications would help ensure continued engagement with financial disclosure. Reporting issuers may also wish to proactively encourage their investors to subscribe to SEDAR+ notifications, both as a matter of good practice and to reduce the volume of ad hoc copy requests.

Conclusion 

The Amendments come at a time when traditional mail delivery in Canada faces increasing uncertainty, with Canada Post’s ongoing transition away from door-to-door delivery reinforcing the practical case for electronic alternatives. They represent another step in the CSA’s modernization of document delivery requirements and the increased use of electronic communications in Canada's capital markets. While the CSA did not extend the access model to proxy-related materials, takeover bid circulars or other documents requiring shareholder action at this time, it indicated that further public consultation on broader application of the model may occur in the future. 

If you have any questions about the Amendments or their impact on your disclosure obligations, please contact a member of our Capital Markets and Securities team.