The Canadian Securities Administrators (CSA) have announced the finalization of amendments to Multilateral Instrument 13-102 – System Fees (MI 13-102) to introduce a multi-year increase to national system fees for SEDAR+ and the National Registration Database (NRD) starting on November 28, 2025. The stated objective is to fund ongoing operations and improvements of the shared national systems while maintaining a predictable fee structure for issuers and registrants.
Overview of the amendments
The amendments keep the flat, per-filing system fee model under the current MI 13-102 and apply a staged increase to all national system fees charged through SEDAR+ and NRD. On November 28, 2025, the CSA will raise each existing system fee by 60%.
Beginning in 2026, the CSA will apply annual increases of 3% over four years. The instrument does not change how filers calculate fees or which filings attract a system fee. It preserves the current schedule by filing type and continues to treat system fees as separate from local regulatory fees charged by securities commissions.
The amendments also add a specific system fee for filing a well-known seasoned issuer (WKSI) base shelf prospectus under National Instrument 44-102 – Shelf Distributions. The WKSI system fee will match the fee for filing a preliminary base shelf prospectus so that expedited WKSIs pay the same system fee at the base shelf stage. Aside from this WKSI alignment, the CSA has not introduced new fee categories or altered fee triggers or payment mechanics.
Comment stage
The CSA invited public comment on the amendments and received four submissions from market participants. Commenters questioned the scale and timing of the 60% first-year increase, asked for a longer phase-in and requested greater transparency about system costs and priorities. They also raised SEDAR+ usability concerns and urged the CSA to address operational issues before higher fees take effect.
In its responses, the CSA acknowledged these concerns but pointed to an 18% revenue decline after the 2023 flat-fee transition and significant growth in IT labour costs. It maintained that a multi-year increase is necessary to recover costs and fund ongoing operations. The CSA did not make material changes to the proposal, confirmed the flat per-filing model would continue and committed to ongoing engagement and incremental system improvements.
Next Steps
Companies should review planned filings for late 2025 and 2026, assess the impact of higher system fees on project budgets, and consider timing where filings could occur before or after the effective date.
If you are interested in learning more about these amendments or any other securities matters, please contact the MLT Aikins corporate finance and securities group. We have experience assisting enterprises from start ups to publicly traded international corporations in a wide range of industry sectors, including financial services, natural resources, agribusiness, manufacturing and technology.
Note: This article is of a general nature only and is not exhaustive of all possible legal rights or remedies. In addition, laws may change over time and should be interpreted only in the context of particular circumstances such that these materials are not intended to be relied upon or taken as legal advice or opinion. Readers should consult a legal professional for specific advice in any particular situation.
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