CIRO Proficiency Model: 4 Months In, Here's What Actually Changed

4 months into the CIRO Proficiency Model. Here's what changed.

By Liam Carter, Founder · Engineering at Registrant Prep · May 6, 2026 · 8 min read

Update, September 29, 2026: The core exam rules have not changed since May: the same nine exams, the same fees ($475 first attempt, $300 per retake, plus applicable taxes) and the same syllabi. In July, Fitch's support site added that personal calculators, paper and pens are not allowed (you use Prometric's on-screen calculator and scratch pad), and CIRO still has not published pass rates. Existing Approved Persons must finish Conduct Training by December 31, 2026, and anyone relying on a CSI course started before 2026 must finish it by the same date. We have also corrected this post's original description of the exam structure: there are no modules or capstone, just one exam per role area.

Four months in, the CIRO Proficiency Model is functioning. Candidates are writing the exams at Prometric test centres across Canada and through Prometric's remote proctoring, and the 9-exam structure that replaced the CSC for investment dealer approval has moved from policy document to lived reality. That does not mean the transition is clean. Pass-rate data is nonexistent, employer reimbursement norms are still forming, and partial CSC completers are up against a December 31, 2026 deadline. (Background: the Canadian Securities Course hub. CSC alumni asking whether they need the CIRE to keep working: the alumni-decision article.) This piece is my attempt to separate what we know from what we are still guessing at.

What's working

The testing infrastructure held up

The single biggest question heading into January 1, 2026, was operational: would Fitch Learning, as the designated exam delivery partner, have enough capacity to absorb the volume of candidates who needed to register under the new framework?

The answer, four months in, is yes. From what I can observe through Registrant Prep's candidate base, exam slots have been available within a two-to-four week window in Toronto, Vancouver, Calgary, and Montreal. Remote proctoring through Prometric ProProctor is an option for every exam. Booking friction is lower than CSI's legacy process was for the CSC.

That matters because most new approvals now run through CIRO exams delivered by Fitch. A new retail RR writes the CIRE plus the Retail Securities Exam. Supervisors, Chief Compliance Officers and Chief Financial Officers write their own exams. Fitch has handled it.

Candidates are moving through

The pipeline is flowing. At Registrant Prep, we saw a meaningful spike in new registrations starting mid-January as firms began onboarding 2026 hires under the new framework. Those candidates are not stuck at intake. The majority who arrived in January have now completed at least one exam. Some are already into their second or third exam sitting.

The pace is slower than I expected for the CIRE specifically, but that reflects study time, not a bottleneck in the system. CIRO does not require a preparatory course before the CIRE. Most working candidates still take two to four months depending on their study schedule.

What changed for candidates

If you are a new entrant or a current CSC holder wondering where you stand, here is the concrete shift.

The 9-exam structure

Pre-2026, the path to Registered Representative approval at an investment dealer ran through CSI courses: the CSC (two exams) plus the Conduct and Practices Handbook (CPH). That was three exams, all from CSI, with the Wealth Management Essentials course due within 30 months of approval.

Post-2026, CIRO's Proficiency Model maps required exams to approval category. The CIRE (Canadian Investment Regulatory Exam) is the new base exam for dealing representatives. There are no modules and no capstone: each of the nine exams is a single sitting, and no preparatory course is required. A new retail Registered Representative needs:

1. The CIRE (110 questions, 2 hours)
2. The Retail Securities Exam (120 questions, 3 hours)

That is two exams before approval, plus a relevant diploma or degree or 4 years of relevant experience. Supervisors add the Supervisor Exam. Chief Compliance Officers and Chief Financial Officers write their own exams. The full complement across all approval categories is nine exams.

Pre-2026 vs Post-2026 comparison:

Pricing changed shape

There is no required prep package. CIRO says the new model does not require preparatory courses, and Fitch's support site says they are "not required or provided." The syllabus, practice exam and Guide for Studying are free on the Exam Hub. What every candidate pays is the exam fee: $475 for the first attempt in a 12-month enrolment and $300 for each of up to two retakes, plus applicable taxes, the same for all nine exams. For firms paying per candidate, that multiplies across a hiring cohort. For self-funded candidates, it is a real cost.

Third-party prep resources, including Registrant Prep's practice question sets and diagnostics at /exams/cire, are optional extras on top of that. We are not the only ones. The market for supplementary CIRE prep material has opened up visibly since January.

What's still murky

No pass-rate data

CIRO has not published CIRE pass rates. It has also said it will not publish a pass mark, because each exam has several versions, each with its own passing grade. I expect pass rates will appear eventually, probably in a quarterly or annual proficiency report. But four months in, no candidate, no firm, and no prep provider has access to aggregate performance data.

That creates a real problem for candidates calibrating how much preparation is enough. With the CSC, you at least knew the pass mark (60% per exam) and could reason backward about where the difficulty threshold sat. With the CIRE, you are calibrating blind.

From our internal Registrant Prep data, I can say that candidates who complete a full diagnostic and score above 72% on their first attempt tend to pass within their first sitting. Candidates who arrive at the exam without any diagnostic benchmark are far more likely to report a failed first attempt. That is not a published statistic, it is a pattern in our anonymised user data. We will publish a proper breakdown once we have more volume.

Partial CSC completers

This cohort has had the most friction in the transition, but the rule is written down. Candidates who had passed CSC Part 1 but not Part 2 before January 1, 2026, fall under IDPC section 2629(1). A CSI course they enrolled in before 2026 still counts if they finish the course and its exam before January 1, 2027, the finished courses would have met the pre-2026 requirement for the same approval category, and the dealer files the approval application before January 1, 2027. Miss any of those and the new CIRO exams apply.

We have candidates in our platform who hold a valid CSC Part 1 pass from 2025 and are weighing whether to finish or start fresh. The deadline makes that a calendar question; confirm the current rule with your dealer before you assume a CSC part-pass counts.

If you are in this situation, the practical answer right now is to contact your sponsoring firm's compliance team and ask them to request written clarification from CIRO directly. Firms are better positioned to escalate than individual candidates.

Employer reimbursement norms

Dealer reimbursement policies were written around CSI course fees and CSI material costs. We have heard, anecdotally, from candidates at mid-size firms that their HR teams are "reviewing" whether the new exam fees and third-party prep qualify under existing policies.

This is not a policy problem CIRO controls, but it affects candidate behavior. Candidates uncertain about reimbursement are either waiting to enroll, enrolling in cheaper alternatives, or paying out of pocket and hoping to reclaim the cost later.

What firms are doing differently

Hiring pipeline shifts

The firms I talk to most often are independent dealer firms and smaller bank-affiliated operations. Their hiring pipelines have adjusted in two ways.

First, every exam for the category has to be passed before CIRO grants approval, so firms need to start the clock earlier. New associates who need to be fully licensed by a particular target date have to begin studying before their hire date, often during the offer-acceptance period. We are seeing more firms reference Registrant Prep as part of their pre-employment onboarding packages.

Second, the post-approval steps changed. New Approved Persons must finish CIRO Conduct Training within 30 days of approval, and the dealer must train new RRs and IRs within 90 days, with both reported on NRD and automatic suspension if either is missed. Firms with tight compliance headcounts are feeling this.

In-house prep vs bought prep

A meaningful segment of larger firms has run internal study groups rather than buying third-party prep for each candidate. The rationale is cost (lower per-head if a senior advisor can run group sessions), plus control over exam readiness before candidates sit. The downside is that internally developed study materials, often repackaged CSI study notes, may not map cleanly to the new CIRE blueprint.

We have seen this pattern in our diagnostic data. Candidates arriving from in-house firm prep programs score well on content areas that overlap with the old CSC, but tend to underperform on the CIRE elements that have no close CSC equivalent. See our CSC vs CIRE comparison for a breakdown of what the blueprints share and where they diverge.

The squeeze on CSI material

CSI still offers the CSC. It still meets the NI 31-103 proficiency requirement for mutual fund dealer and exempt market dealer dealing representatives. But for approval at a CIRO investment dealer, the CSC stopped counting on January 1, 2026. The market knows this.

The CSC is not dead, but its position as the canonical first step for Canadian securities licensing has shifted. What replaces it is still consolidating.

What I'm seeing in the candidate data

A few patterns from Registrant Prep's anonymised user base, as of May 2026:

60% of candidates start the CIRE path without taking a mock exam first. They enroll, buy a prep package, and start studying, often without knowing where their knowledge gaps are. The ones who do take a diagnostic before their first study session cover material more efficiently.

The Supervisor Exam is the first exam most experienced advisors are writing. Existing Approved Persons do not have to rewrite anything to stay in their current role, so senior reps with CSC-era approvals are not starting with the CIRE. When they move into supervision, they need the Supervisor Exam (but not the CIRE, if they have 2 years of relevant experience), so that is where compliance officers are directing them. We see a disproportionate number of high-tenure candidates in our supervisor exam practice sets relative to what the overall population of CIRE candidates would predict.

Predictions for months 5-12

1. CIRO publishes initial CIRE pass-rate data. My best guess is a proficiency report before Q4 2026. The regulator has every incentive to demonstrate that the new framework is functioning, and pass rates are the most legible metric for that. When the data appears, expect a significant recalibration among prep providers.

2. Partial CSC completers race the deadline. The rule is already written: IDPC section 2629(1) lets a CSI course started before 2026 count only if it is finished, and the dealer applies, before January 1, 2027. The pressure on mid-size firms is getting those applications in on time. I am tracking CIRO's publications page for any further guidance.

3. Search volume for CIRO exam terms continues growing. DataForSEO data we reviewed in preparing this article showed a 26x rise in searches for CIRE-related exam prep terms over the past six months. That growth reflects a market still in discovery mode. By fall 2026, search intent will be cleaner and more competitive.

4. Prep material consolidation. Right now the market has Registrant Prep, a handful of other providers, and a lot of self-made notes circulating in advisor Facebook groups. Over the next 6-8 months, a few of these will establish clear differentiation. The ones that map tightly to the published CIRE blueprint and offer diagnostic capability will hold.

5. Firm reimbursement policies get updated at most large dealers. HR teams at the large banks are slow, but by Q3 they will have updated their benefits language to explicitly cover CIRE prep fees. This will release some of the pent-up demand from candidates who have been waiting.

6. The CSC continues its slow decline for CIRO registration purposes. New entrants will almost entirely enroll in the CIRE path. CSI will retain share among mutual fund dealer and exempt market dealer reps, where the CSC still meets NI 31-103, but for the mainstream CIRO dealing representative population, the transition is functionally complete.

What this means for you

If you are a new entrant, the path forward is unambiguous: write the CIRE, then the role exam your approval needs. Start with a diagnostic before you buy prep materials, because not everyone has the same gaps. The CSC replacement hub on Registrant Prep has a full walkthrough of the registration pathway, and the exam page at /exams/cire maps the blueprint against practice content.

If you are an advisor firm tracking your licensing pipeline, the two things that matter most right now are: how many of your current hires are still working through their exams before approval, and whether your HR team has updated its reimbursement policy to cover CIRE fees. The first question affects your operational capacity. The second affects candidate behavior and retention during the study period.

Four months in, the CIRO Proficiency Model is real and it is not going back. The candidates and firms who treated January 1 as a firm date, not a soft deadline, are ahead. If you are still figuring out where you stand, take the free mock exam and get a baseline. That is the most useful 20 minutes you can spend before deciding how to proceed.

What to read next

• CIRE vs CSC: every difference, side by side
• What replaced the CSC: the CIRO Proficiency Model hub
• The 9 CIRO exams, ranked by pass difficulty
• Full CIRE exam guide