On March 19, 2026, the Canadian Securities Administrators (the "CSA") announced the launch of Coordinated Blanket Order 51-9331 (the "Blanket Order"), introducing a multi-year pilot program (the "SAR Pilot") that allows eligible venture issuers to voluntarily adopt semi-annual financial reporting.
The SAR Pilot provides qualifying venture issuers with an exemption from the requirement to file interim financial reports and related management's discussion and analysis ("MD&A") for the first and third quarters of their financial year (the “Quarterly Reporting Exemption”) together with some additional exemptions from financial and MD&A requirements.
Participating issuers must continue to file complete six-month interim financial reports and related MD&A and remain subject to all other existing disclosure requirements under applicable stock exchange and securities rules.
Eligibility
To participate in the SAR Pilot, a company must, at the end of each applicable first and third quarter of its financial year, (i) have been listed on the TSXV or CSE for at least 12 months; (ii) be in good standing; and (iii) have a revenue of less than $10 million.
Companies relying on the Quarterly Reporting Exemption must also issue and file a news release with prescribed language.
Limitations on the Exemption
Issuers should be aware of several important restrictions and obligations associated with the Quarterly Reporting Exemption:
- An issuer must cease relying on the Quarterly Reporting Exemption if it changes its financial year-end or files a base shelf prospectus.
- An issuer relying on the exemption must not file a shelf prospectus supplement or distribute securities under an existing shelf prospectus supplement.
- An issuer that has filed a short form prospectus must not rely on the exemptions during the period of distribution.
- The exemptions under the Blanket Order do not apply to the disclosure requirements in respect of interim financial reporting or related MD&A pursuant to certain form requirements in relation to short form prospectuses, information circulars, takeover bid circulars and issuer bid circulars.
Can Your Company Take Advantage of this New Pilot Program?
- Assess fit and investor expectations: Balance potential cost and process efficiencies against investor expectations and any potential impact on market perception.
- Plan for transaction windows: The exemption cannot be relied on during certain distribution periods and in connection with specified prospectus activity—build this into capital markets and M&A timelines.
- Maintain disclosure discipline: Timely disclosure and material change reporting continue to apply; semi‑annual reporting is not a relaxation of core continuous disclosure obligations.
The CSA has indicated that the SAR Pilot is intended to inform a future rule-making project related to semi-annual financial reporting for eligible reporting issuers more generally. If successful, the SAR Pilot could pave the way for expanded semi-annual reporting options across a wider range of issuers.
Reach out to our team at DuMoulin Black to discuss these changes and how they may apply to your company.
Authored by Justin Kates, Managing Partner at DuMoulin Black and Knowren Ansari, Articled Student at DuMoulin Black.