Expert Analysis

CSA’s ‘access equals delivery’ model takes effect for continuous disclosure documents

By Amy Marcen-Gaudaur and Jacob Waltman ( October 20, 2026, 11:49 AM EDT) -- On June 25, 2026, the Canadian Securities Administrators (CSA) published final amendments to National Instrument 51-102 Continuous Disclosure Obligations and National Instrument 54-101 Communication with Beneficial Owners of Securities of a Reporting Issuer and related changes to the corresponding companion policies (Amendments), providing non-investment fund reporting issuers the option to follow an alternative “access equals delivery” model (AED Model) to satisfy the delivery requirements in respect of annual financial statements, interim financial reports and related management’s discussion and analysis (MD&A). The Amendments came into force on Sept. 22....