TL;DR: On December 11, 2025 the Canadian Securities Administrators (CSA) and the Canadian Investment Regulatory Organization (CIRO) released Joint Staff Notice 31-369 — a public explainer on how finfluencers are regulated in Canada. Educational content about TFSA, RRSP, fundamentals is permitted to anyone. Specific buy/sell recommendations on specific securities are illegal without CSA registration (NRD number). A registered firm is responsible for your protection when you deal with a licensed representative; with an unregistered finfluencer, no one is responsible until harm occurs. Verifying any "advisor" takes 30 seconds via info.securities-administrators.ca.

What happened December 11, 2025

CSA is the umbrella body of 13 provincial and territorial securities regulators (ASC in Alberta, BCSC in BC, OSC in Ontario, etc.). CIRO is the self-regulatory organization (SRO) that regulates investment dealers (formerly IIROC) and mutual fund dealers (formerly MFDA). Together they cover the entire Canadian investment market.

On December 11, 2025 they released Joint Staff Notice 31-369: Guidance on Use of Finfluencers — a public reminder to every registered firm and representative who works with social media content. The document doesn't introduce new law; it interprets existing rules (National Instruments 31-103 and 33-109) for the era of TikTok / Instagram / YouTube / Telegram.

⚠️ EMD compliance disclaimer: This is educational material. It's not legal advice. For individual decisions — discovery call with a Licensed DR (NRD #4575551).

What the document says

Registered firms are responsible for all content

If a "financial advisor" appears in your TikTok feed and they're registered in NRD — everything they say is the responsibility of their firm. Not themselves alone, not TikTok, not their sponsor — the firm. Regulators can fine the firm, revoke its licence, ban it from social media activity.

What this means for you: registered advisors typically stay within bounds — because their company pays for any mistake. If someone is shouting "buy this stock now!" on TikTok, they probably just don't have a licence.

Educational vs Recommendation

CSA itself acknowledges the line between "education" and "recommendation" is fuzzy. Notice 31-369 gives three fact patterns to distinguish:

| Education (permitted) | Recommendation (requires registration) | |---|---| | "Here's how a TFSA works" | "Open a TFSA via this broker in 30 seconds — use my link" | | "RRSP has tax deferral until withdrawal" | "Invest in [specific fund] via RRSP — I got you a discount" | | "Exempt market requires Eligible Investor status" | "I have an exempt market deal at $50K — DM me" | | "Calgary real estate has historically grown 6% per year" | "Buy this specific condo for $400K, I'm selling it" |

The first column is what Andrii Andriushchenko does on this site: explaining concepts, posting educational videos, blogging. The second is what only I, with NRD #4575551 at Axcess Capital Advisors, am legally allowed to do — and only after we've gone through Know-Your-Client, I've confirmed your Eligibility (NI 45-106), and we've discussed specific solutions in private.

Disclosure is now mandatory

If someone on social media sells you a product via a link and receives a commission — they're required to disclose that openly. Joint Notice 31-369 directly calls this "material connection disclosure". Look at this site's footer — there's a clear disclaimer that Andrii is a registered representative at Axcess Capital Advisors Inc. and receives commissions on exempt market securities sales.

If a TikTok advisor doesn't disclose the financial connection to what they're recommending — and CSA finds out — that's a violation of NI 31-103. In 2024-2025, regulators have already fined several "finfluencers" for exactly this.

What this means for you as a consumer

1. Verify any advisor in 30 seconds

Go to info.securities-administrators.ca/nrsmobile/nrssearch.aspx. Type a name or NRD number. You'll see:

Registration status (yes/no)
Category — Dealing Representative (like Andrii), Advising Representative, Portfolio Manager
Firm — where they work
Provinces — where they're allowed to operate
Any disciplinary actions — over their entire career

If a name is not found — they cannot legally recommend investments in Canada. Period.

Step-by-step walkthrough — Verify me in 3 minutes.

2. Look for disclosure

Before clicking the link in a TikTok advisor's bio — check:

Is their firm and NRD number listed?
Is there a disclaimer about material connection?
Is the content style educational or promotional?

Missing disclosure + promotional style = extreme caution.

3. Distinguish licence types

Canada has four main categories of financial licences:

EMD (Exempt Market Dealer) — like Axcess Capital, where Andrii works. Distributes exempt market securities (MICs, private REITs, development LPs) to Eligible/Accredited Investors.
CIRO Investment Dealer (formerly IIROC) — can distribute ETFs, stocks, mutual funds, options. Everything traded on TSX.
CIRO Mutual Fund Dealer (formerly MFDA) — mutual funds only.
Insurance Agent — life insurance, segregated funds, annuities (separate licence, not securities).

No single licence covers everything. If an advisor talks about everything — TFSA, ETFs, real estate, crypto, insurance — they either hold 3-4 separate licences (rare), or they're just sharing education (fine), or they're outside their licence scope (red flag).

Full coverage: EMD vs CIRO vs Insurance: comparison table.

4. Understand conflict of interest

Every registered advisor must disclose conflicts of interest. As an EMD, I earn commissions on exempt market sales. CIRO advisors earn trailers/fees on mutual funds or commissions on trades. Insurance agents earn commissions on insurance products.

That's normal — it's a business. But you have a right to know:

What does a session/consultation cost?
What kind of compensation does the advisor receive for a recommendation?
Do they owe you a fiduciary duty (like a Portfolio Manager) or a suitability duty (like a Dealing Representative)?

If an advisor avoids these questions — that's a signal.

5 red flags of an unlicensed finfluencer

1. Promises specific returns

No licensed representative has the right to promise a specific return on a specific security. NI 31-103 directly forbids performance claims in marketing materials.

If you see "this product guarantees 18% return" — that's almost always a violation.

2. Time pressure

"Today only", "limited spots", "price goes up tomorrow" — standard sales tactics that licensed firms typically avoid.

3. Direct messages with offers

If an unknown "advisor" DMs you with a specific deal — that's outside the scope of a regular advisor-client relationship.

4. Invitations to Telegram/Discord groups

"Join my private group where I share picks" — often a front for unregistered advice.

5. Payments via personal Venmo / e-Transfer / crypto

Registered firms don't accept payment via personal accounts. Everything flows through the firm's trust accounts.

What to do if you suspect a violation

Screenshot everything — TikTok video, DMs, links, payment requests.
NRD check — if not found, that confirms the problem.
File a complaint with CSA — securities-administrators.ca/enforcement.
File with OBSI — if you've already lost money. Free for consumers: obsi.ca.

How this affects my practice

I'm a Licensed Dealing Representative (NRD #4575551, Axcess Capital Advisors Inc.). 95% of my content is educational. I don't recommend specific securities on social media — that I can only do in private consultation after going through KYC.

If you see my videos, that's education, not a recommendation.

Conclusion

Joint Staff Notice 31-369 is a friend to consumers, not a foe. Remember three things:

NRD check in 30 seconds — info.securities-administrators.ca.
Education vs recommendation — if someone discusses a specific security with a buy link, they need registration.
Disclosure is mandatory — conflicts of interest must be clear.

Full coverage: Joint CSA/CIRO Notice 31-369 explainer page.

Joint CSA/CIRO Staff Notice 31-369: full consumer guide for newcomers in Canada