Canada’s self-regulatory organisation has widened the range of information and decision-support tools that order execution only dealers can offer do-it-yourself investors. The updated guidance took effect on 12 March and replaced the former OEO guidance.[1][2]
The central boundary has not changed: an execution-only dealer must not recommend that a client buy, sell, hold, exchange or otherwise take a specific investment decision. The update explains how education, alerts and self-help tools can remain on the information side of that line.[1][3]
Permissible support depends on design, not the product label
Examples and regulatory boundary
| Support | Potentially permissible use | Where it can become a recommendation |
|---|---|---|
| Educational resource | Explain a product, market mechanism or risk in neutral terms. | Steer the client toward a particular security or transaction.Source 1 |
| Notification or alert | Flag an account event, risk metric, price movement or information update. | Use personalised wording that endorses a specific action.Source 1 |
| Screen or self-help tool | Let the client select objective criteria and review resulting information. | Embed hidden ranking, default choices or prompts designed to induce a trade.Source 1 |
| Portfolio information | Show holdings, concentration, costs or performance using reliable data. | Convert the information into a firm-endorsed rebalance or product choice.Source 1 |
Controls CIRO expects around decision supports
| Measure | Value | Context |
|---|---|---|
| Client responsibility | The client remains the decision-maker | The OEO dealer does not assume a suitability or advice mandate through the tool.Source 1 |
| Clear presentation | Purpose and limitations should be understandable | Disclosures should match how the tool actually works.Source 1 |
| Objective criteria | Selection and ranking logic should be supportable | Criteria should not be a disguised endorsement of proprietary or favoured products.Source 1 |
| Conflicts and monitoring | Identify conflicts and review tools over time | Outputs, data and customer use can change after launch.Source 1 |
How an alert is presented changes its meaning
CIRO’s approach is functional. A tool labelled “education” can still be a recommendation if its presentation, defaults, targeting or repeated prompts would reasonably be understood as the dealer encouraging a particular trade. Conversely, a personalised alert is not automatically advice when it reports a factual condition without endorsing an action.[1]
For example, reporting that a holding exceeds a client-selected concentration level leaves the investment decision with the client. A prompt directing that client to sell the holding and buy a named replacement moves towards an endorsed transaction. The distinction is an illustration of the guidance’s reasonable-client test, rather than an approval of any particular interface.[1]
The dealer’s controls therefore have to cover the output clients actually see: the data, selection and ranking logic, wording, repeat prompts and commercial incentives. CIRO expects ongoing review, testing, outcome monitoring and escalation where problems arise. A disclosure needs to describe the tool faithfully; it cannot counteract an interface that communicates an endorsement.[1]
A restricted product shelf requires a separate assessment
The guidance does not contemplate a shelf wholly or largely restricted to proprietary or affiliate products, or a very limited range. Such a shelf can shape results before the client chooses criteria. CIRO says a dealer considering that model should submit a notice of material change to its business activities, with the related conflicts assessed in clients’ best interests.[1]
The execution-only service also retains its account-appropriateness responsibilities at opening and on an ongoing basis. That concerns whether the investor should use the OEO service, while the investor remains responsible for individual investment decisions without the dealer providing personalised recommendations or suitability assessments.[1]
For investors, the practical benefit is more useful information within the account: holdings, concentration, costs, performance and risk signals can inform a decision. Understanding the inputs, assumptions and commercial context of a tool remains part of using that information well.[1][3]
Sources & further reading
- Guidance on order execution only account services and activities Canadian Investment Regulatory Organization · 12 Mar 2026 · Accessed 16 Oct 2026
- New guidance on order execution only account services and activities Canadian Investment Regulatory Organization · 12 Mar 2026 · Accessed 16 Oct 2026
- CIRO publishes new guidance for order execution only dealers Canadian Investment Regulatory Organization · 12 Mar 2026 · Accessed 16 Oct 2026