2026 Regulation

Joint CSA/CIRO Staff Notice 31-369

What the December 2025 finfluencer rules in Canada mean — and how to protect yourself

On December 11, 2025 the Canadian Securities Administrators (CSA) together with the Canadian Investment Regulatory Organization (CIRO) released Joint Staff Notice 31-369 — a public reminder to every financial professional and brand active on social media. It isn't a new law; it's clarification of existing rules: if someone publicly talks about securities on TikTok / Instagram / YouTube / Telegram, registered firms remain responsible even when the content is created by someone other than the registered representative. For you as a consumer, it draws a clear line between legal education and illegal selling.

Updated:

Andrii Andriushchenko
Andrii Andriushchenko
Licensed Dealing RepresentativeAxcess Capital Advisors Inc.NRD #4575551 — verify

What you'll learn

What a finfluencer is and why regulators noticed

A finfluencer is anyone creating financial content on social platforms: TikTok, Instagram, YouTube Shorts, Telegram, X. While content stays purely educational ('here's how a TFSA works'), regulators don't intervene. The line is crossed when 'buy this product', 'guaranteed 15% returns', or 'I personally recommend X' enters the picture — that requires Dealing Representative or Investment Advisor registration with CSA/CIRO. In 2024-2025 regulators caught dozens of cases where finfluencers promoted specific securities with no license at all. Notice 31-369 is a public reminder that this is a violation.

What a registered DR (like me) is allowed to do

A registered Dealing Representative (in my case, NRD #4575551 with Axcess Capital Advisors Inc.) can publish educational content about asset categories (TFSA, RRSP, exempt market, real estate). Can explain regulatory frameworks (NI 31-103, NI 45-106). Can give general guidance on 'what to consider when picking an advisor'. Cannot: give personal buy/sell recommendations without a formal KYC + Suitability Assessment with the specific client, promise specific returns, or guarantee outcomes. Every public material I put out — including this page — is reviewed by Axcess Capital's CCO before publication.

What's forbidden for everyone (registered or not)

Return guarantees — e.g. '$10K becomes $100K in a year' — are absolutely forbidden. Promoting a specific security without a disclosed compensation arrangement is a violation. Pseudo-consultations of the 'DM me, I'll help' kind are a trap: a conversation that starts in DMs and turns into 'buy this fund' creates liability as an unregulated sale. The worst category is selling crypto/forex/options schemes disguised as 'education'. That's the primary target of Notice 31-369.

How to check whether a finfluencer is licensed

Open the CSA NRD search (info.securities-administrators.ca/nrsmobile/nrssearch.aspx). If someone calls themselves 'advisor', 'consultant', 'portfolio manager', or 'dealing representative', they MUST be in that database. If they're not, any 'personal recommendation' they give you is legally improper regardless of follower count. Red flag: 'certified', 'expert', 'mentor', 'coach' — these aren't regulatory terms and tell you nothing about a license. Check my name: NRD #4575551, Andrii Andriushchenko, Axcess Capital Advisors Inc.

What the Notice means for you as a consumer

First: heightened regulator attention on social-media content — expect more enforcement actions against unlicensed finfluencers through 2026. Second: it's easier to spot real professionals vs. 'gurus' — a real DR publicly states NRD #, firm, provinces of registration, and disclaimers in every post. Third: your right to complain. If someone unlicensed sold you a product through TikTok DMs, OBSI (the Ombudsman for Banking Services and Investments) can help you recover funds. It's a public, free channel.

Quick comparison: licensed DR vs unlicensed finfluencer

AspectRegistered DR (like me)Unlicensed finfluencer
NRD #✅ Public, verify in 30 sec❌ None
Employer firm✅ Named + CSA-registered❌ 'Self-employed' / nothing
Compensation disclosed✅ In OM / on consult❌ 'Commission from X sales' hidden
Social-media disclaimer✅ On every post❌ None
KYC before recommendation✅ NI 31-103 mandatory❌ 'Just buy it'
CCO oversight✅ Every asset reviewed❌ None
Can guarantee returns❌ Forbidden✅ Often does
Recourse if losses✅ OBSI + regulator + firm❌ Disappears / no one

Frequently asked questions

Can a popular Ukrainian/Russian-speaking TikTok finfluencer in Canada be properly licensed?
Yes — and that's the best case for the audience. Verify by searching their full name in the CSA NRD database. If the result shows firm + category + registration date, it's a real DR. If nothing comes back, they're operating outside regulation. Many Ukrainian/Russian-language finfluencers in Canada offer 'financial advice' WITHOUT a license — not necessarily fraud, but legally unregulated activity with no recourse for you.
What do I do if I already invested through an unlicensed finfluencer?
1) Capture all chat history + payment documents. 2) File a complaint with OBSI (obsi.ca) — free, you can use a translator. 3) If it involved securities, parallel-file with the provincial securities regulator (ASC in Alberta, OSC in Ontario, BCSC in BC). 4) Guaranteed-return promises are almost always Securities Act violations. Regulators are actively pursuing these cases in 2026.
Can I trust the content if the finfluencer is licensed?
More — yes. A license means: completed professional education (EMP, CSC, WME, LLQP), regulatory background check, compliance training, attachment to a registered firm, regulator oversight. But it's not a guarantee that a specific recommendation fits you — only a formal KYC + Suitability Assessment with your numbers can confirm that. Always insist on KYC before making a decision.
Does Notice 31-369 cover crypto influencers?
Only when they promote securities. 'Bitcoin is the future' is educational and isn't covered. 'Buy this token from this project, I get a cut from sales' is covered (it's a securities distribution). Most crypto projects in 2024-2026 were classified by CSA as securities, so NI 31-103 + NI 45-106 apply. Many Canadian crypto finfluencers are in a grey zone.
Why are you publishing this page?
Because I'm a Licensed Dealing Representative (NRD #4575551, Axcess Capital, AB·BC·ON), and my professional reputation depends on the Ukrainian/Russian-speaking audience in Canada being able to tell regulated professionals from unregulated 'gurus'. This is public education that simultaneously protects my registry category and helps you not lose money. This page has been reviewed under Axcess Capital's compliance framework.
Where do I go for more specific questions?
30-minute discovery call, free — we'll go through your situation in person. Or /en/perevirka to verify my registration yourself. Or the CSA NRD search directly. If you've spotted a suspicious finfluencer, report to OBSI or the provincial regulator (ASC.ca for Alberta).

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