On September 24, 2026, the Toronto Stock Exchange ("TSX") published a request for comments on proposed changes to the TSX Company Manual (“Proposed Amendments”). 

The Proposed Amendments are intended to modernize and simplify the TSX's listing framework while providing greater clarity and predictability for market participants. 

Key proposed changes include:

• Aligning the definition of independent director with current securities law requirements; 
• Updating the financial tests and continued listing requirements for listed issuers; 
• Revising the requirements for issuers in the diversified listing category; 
• Replacing the existing resource issuer category with separate and more tailored requirements for mining issuers and oil and gas issuers; 
• Updating market capitalization and public distribution thresholds;
• Shortening the notice period required for voluntary delistings; 
• Streamlining the TSX decision review process by consolidating reviews under a single senior officer and eliminating appeals to the TSX Board; and 
• Implementing various housekeeping and consequential amendments to support the overall modernization of the framework.

The comment period is open until October 26, 2026. If you wish to discuss the Proposed Amendments or have your thoughts included in BD&P's comment letter, please reach out to any member of our Business Law group.