Securities Filing Fees Jump and Annual Indexation Introduced
The draft Regulation amending the Securities Regulation under the Securities Act (chapter V-1.1) proposes updates to the financial obligations and administrative procedures for participants in Quebec’s securities market. Its primary purpose is to revise fees payable by dealers, advisors, representatives, and recognized stock exchanges, establish costs associated with inspections and investigations, implement annual indexation based on the Canadian Consumer Price Index, and introduce administrative monetary penalties for issuers or firm underwriters that fail to submit reports on exempt distributions.
The amendments revise Chapter II of Title VI of the Securities Regulation, now titled “Fees and Costs Payable.” Section 267 updates fee amounts for various filings and introduces higher minimum fees for well-known seasoned issuers filing prospectuses or pricing supplements. Fees previously set in the $1,200–$1,400 range are adjusted upward, reflecting inflation and administrative cost considerations, and subparagraphs addressing certain Quebec-specific references are aligned with Canadian-wide standards. Section 268 further ties certain fees to amounts paid during the last financial year, creating a dynamic mechanism to maintain parity with past payments, while Section 268.1 raises specific fees to $2,000.
Additional modifications clarify the treatment of credit unions under Section 270, adjusting terminology from “permanent shares” to “capital shares” and aligning references to federations rather than confederations. Section 271.2 increases filing fees for issuers and investment funds, introducing explicit charges for revocation of cease trade orders ($2,000) and filing geological reports ($1,000). Section 271.4 and related provisions standardize annual fees for mutual fund dealers, scholarship plan dealers, and representatives, with most recurring fees set at $2,000.
The regulation introduces structured fees for pre-filing consultations and applications for exemptions. Section 271.6.1 establishes a $2,000 fee for pre-filings with the Autorité des marchés financiers, deductible from the related filing fee, ensuring the Authority is compensated for advisory services even when filings do not proceed. Sections 271.12 through 271.12.4 specify fees for recognized stock exchanges and parallel trading systems based on Canadian market share, ranging from $22,500 for smaller exchanges to $375,000 for those with over 75% market share. Smaller exempt exchanges and parallel trading systems are also included with standardized annual fees ($7,500 and $10,000 respectively).
The draft Regulation also formalizes cost recovery for inspections and investigations, setting a standard rate of $120 per hour per inspector, payable within 30 days of the statement of fees. This ensures market participants bear a fair share of oversight costs, reinforcing accountability and compliance with securities law.
Quebec (Draft) March 11, 2026
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