Karsten Wenzlaff, Advisor
August 26th, 2025
August 21, 2026 | NCFA Insight | Capital Markets And Market Infrastructure, Regulation And Policy, Competition And Market Structure

On August 18, 2026, the Canadian Securities Administrators published its 2025–2026 Year in Review. One capital formation result stands out. After regulators increased the limits for the Listed Issuer Financing Exemption, hundreds of listed issuers used it to raise almost $4 billion in the first year, at eight times the pace under the original limits.
That is unusually useful regulatory evidence. It doesn't prove the higher limits caused every additional financing, since issuer demand and market conditions also affect activity. But the market used the exemption far more heavily after regulators made it more practical. The result also strengthens a larger question NCFA recently explored around whether Canada can turn access into productive participation rather than stopping at permission on paper.
NCFA reviewed the expanded LIFE exemption when the CSA initially increased how much eligible listed companies could raise without preparing a prospectus for each financing.
The new usage data take that reform beyond policy design. Companies had a less burdensome financing route available and hundreds chose to use it.
The LIFE exemption gives eligible reporting issuers a more efficient way to raise public capital while retaining specified disclosure and investor protections. This matters most when the fixed costs of a conventional financing become large relative to the amount a smaller company needs to raise. A financing route can exist legally and still see limited use if its cost, complexity or timing makes the economics unattractive.
The first year under the higher limits provides evidence that those economics are essential. Hundreds of issuers used LIFE and almost $4 billion was raised, compared with a much lower pace under the previous limits. The important result is not simply that Canada permitted more financing. Issuers actually used the additional room.
That gives regulators a stronger basis for the next round of evaluation. Which companies used LIFE, how large were the financings, what did it cost them to raise the money, how did investors fare and how much activity would have occurred through another route anyway? Those questions can help distinguish a rule that merely looks simpler from one that materially improves capital formation.
The CSA is reducing different forms of friction elsewhere in the market. Eligible venture issuers with less than $10 million in annual revenue can voluntarily file financial results semiannually rather than quarterly under an interim regime. Regulators can use what they learn from that regime when considering permanent rules, making issuer cost and actual market use part of the feedback process.
The proposed self certified investor exemption approaches participation from the investor side. People who satisfy specified education or experience criteria could invest even if they don't meet the financial thresholds for accredited investors, with investments capped at $50,000 per calendar year across multiple businesses. The proposal would give Canadian issuers another potential source of private capital while widening access for investors regulators believe have enough knowledge or experience to understand the risks.
Accredited investor rules largely use wealth and income as proxies for the ability to bear risk, while the proposed exemption would also recognize relevant knowledge or experience. If adopted, its value should eventually be judged by more than the number of investors who become legally eligible. Issuer uptake, investment activity, losses, complaints and other investor outcomes would show whether wider access produces a useful market.
The same focus on actual market use is reaching new securities infrastructure. NCFA covered the launch of Project Tokenization when the CSA opened stakeholder engagement through the Collaboratory and identified a possible route toward live testing. The CSA now says the project has engaged more than 240 organizations spanning issuers, fintech companies, custodians, marketplaces, clearing agencies, professional firms and other participants.
The CSA Collaboratory gives novel products and market structures a way to engage regulators before launch and can support controlled testing where appropriate. That's important because tokenized securities depend on more than an issuer receiving permission to create a digital asset. Custody, ownership records, trading, settlement, compliance and investor protection all have to work well enough for a product to operate economically.
Tokenization is a more complex extension of the LIFE lesson. LIFE shows what happened after one capital raising constraint was relaxed. The U.S. is also reconsidering how securities rules apply to crypto asset capital raising, including proposals that could expand how much eligible issuers can raise under lighter offering requirements. In Canada, Project Tokenization can show whether regulators and market participants can identify which requirements are essential, which need adapting and which create enough cost or uncertainty to prevent otherwise viable infrastructure from being built here.
Ontario's commitment to join Canada's securities passport system tackles another longstanding source of friction. Our Ontario securities passport story traced how the province moved from pursuing a national regulator to joining the existing passport model. The CSA says Ontario's participation is intended to strengthen national harmonization, remove interprovincial barriers and reduce regulatory burden for companies doing business across Canada.
For firms operating nationally, duplicated provincial processes can become an operating cost even when the underlying securities requirements are similar. The useful evidence after Ontario joins will be whether companies encounter less duplication, lower compliance costs and easier national market access. Regulatory reform becomes much more informative when policymakers can compare what they changed with what companies and investors actually did afterward.
Lower friction does not mean removing protections wherever market participants find them expensive. The CSA issued 763 investor alerts, cautions and warnings during the year, more than 85% involving crypto assets, and facilitated the deactivation of 11,728 malicious investment websites representing 19,860 URLs.
Some rules clearly protect investors and market integrity. Others may now be costing the market more than they protect.
LIFE gives Canada a rare piece of evidence about that balance. Almost $4 billion and an eightfold increase in financing activity give regulators a reason to look for other places where better calibrated rules could produce more usable markets without sacrificing the protections that keep those markets credible.
If higher LIFE limits were followed by an eightfold increase in capital raised through the exemption, which other securities rules should Canada now test against actual issuer and investor behaviour?
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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