CIRO’s 8 October guidance says extended-hours access does not alter a dealer’s existing obligations. It asks firms to consider how lower liquidity, wider spreads and different price discovery affect their controls and disclosures outside the 9:30 a.m.–4:00 p.m. ET core session.[1]
What the guidance addresses
| Area | Operational point |
|---|---|
| Disclosure | Hours, accessible marketplaces, limitations and differences in order handlingSource 1 |
| Order types | Explain limit-order protection; dealers may restrict order typesSource 1 |
| Foreign affiliate staff | Assess registration requirements and any needed exemptive reliefSource 1 |
| Supervision | Existing rules and oversight continue outside core hoursSource 1 |
| CIRO requests during 8 a.m.–5 p.m. ET | Generally handled within the same business daySource 1 |
| Requests outside those business hours | Best efforts; ordinarily not reviewed in real time or until the following business daySource 1 |
Market access and regulatory support have different hours
A longer dealing session can create an operational dependency if a transaction needs an interpretation or exemption when the regulator is not normally reviewing requests in real time. Firms should distinguish their customer trading window from CIRO’s stated handling window.[1]
A limit price can constrain the price at which an order executes, but cannot guarantee execution. That is especially relevant where a displayed quote represents limited size or where the client’s broker reaches only part of the available market. A clear account of venues and order handling is more useful than a broad promise of overnight access.
The guidance connects these issues to IDPC sections 3121 and 3129 and UMIR 6.1. It does not announce a compulsory extension of hours for every dealer or a universal implementation date. The practical obligation is to apply the relevant rules to the service actually offered.[1]
Sources & further reading
- GN-3100-26-001: Guidance on Extended Hours Trading Canadian Investment Regulatory Organization · 8 Oct 2026 · Accessed 27 Oct 2026