On October 1, 2026, the Canadian Securities Administrators (CSA) released a proposed new rule, National Instrument 26-101 - Information Technology System Integrity, for public comment. 

 

The proposed rule would create a single, harmonized framework governing the IT systems of Canada's major market infrastructure entities, including stock exchanges and other marketplaces, clearing agencies, trade repositories, information processors and matching service utilities, replacing the current patchwork of technology-related requirements. 

 

The CSA has indicated that the objective is to strengthen confidence in, and the stability and integrity of, the IT systems that underpin Canadian securities trading, clearing, processing and reporting activities.

For public issuers, the practical takeaway of the proposed new rule is that oversight of IT systems, AI deployment, cybersecurity controls, incident response planning, third-party technology risk and business continuity arrangements is increasingly becoming a governance and disclosure matter. As regulators develop more sophisticated expectations for market infrastructure entities, issuers should expect continued scrutiny of how technology and AI risks are identified, managed and, where material, disclosed to investors.

The CSA is seeking comments on the proposed new rule until January 29, 2027.

If you have questions regarding your organization's technology infrastructure, cybersecurity governance, operational resilience framework, or the potential impact of the proposed National Instrument 26-101 - Information Technology System Integrity, please contact any member of our Business Law Group.