If you were an Approved Person before this year started, there is one item on your 2026 compliance list that ends in an automatic suspension. It's free, it's online, and it takes an afternoon.
The deadline is December 31, 2026. Leave it until December and you'll be racing a compliance team that is closing out the year at the same time, which is a bad week to need something filed on your behalf.
The deadline, and what happens if you blow past it
From CIRO's page for existing Approved Persons:
"Existing Approved Persons, as of January 1, 2026, must complete new, mandatory Conduct Training by December 31, 2026."
And the consequence, which appears in the same words on CIRO's dealer page:
"Failure to complete, and report on the completion of the Conduct Training, by the above prescribed deadlines, will result in an automatic suspension."
No warning letter. No grace period. No fine you can pay to make it go away. Automatic.
If you were approved during 2026 rather than before it, your clock is shorter and already running: "All new Approved Persons will need to complete the Conduct Training within 30 days of approval."
Read that suspension clause again
Here's the part worth slowing down for, because it's where this goes wrong for people who did everything right.
The trigger isn't completing the training late. It's "failure to complete, and report on the completion."
Two verbs. You own the first one. Your dealer owns the second:
"Once Conduct Training is successfully completed, Approved Persons will be issued a completion confirmation, that they need to share with their dealer in order to report their completion on NRD and on CIRO Services."
So the sequence runs: you finish the course, you receive a confirmation, you send that confirmation to your dealer, and your dealer files it on NRD. Miss any link in that chain by December 31 and the clause reads the same way it always did.
Finishing the course on December 30 and emailing the confirmation into a compliance inbox that nobody opens until January is a genuinely plausible way to get suspended while holding proof you did the work.
Do it in October. Then follow up and confirm somebody filed it.
There are actually two filings
For new Approved Persons, CIRO is explicit about who files and when: "Completion must be reported by the dealer on NRD within 30 days of approval."
And if you want the continuing-education credit, that's a second, separate filing:
"Dealers will need to report its completion for Mandated Annual CE purposes on CIRO Services-CE, in addition to reporting on NRD for post approval purposes within the prescribed timelines."
NRD keeps you registered. CIRO Services-CE gets you the CE hours. Two systems, two filings, one deadline, and neither of them is a button you can press yourself.
When you chase your compliance team, ask about both by name. "Did the conduct training get filed?" invites a yes that covers one of them.
The upside: it's free, and it pays for your CE year
Three things make this a genuinely easy win once you stop putting it off.
It costs nothing. CIRO's answer to its own FAQ is one sentence: "There are no fees for Conduct Training."
You can do it from anywhere. "Conduct Training is an online course that you can complete virtually from any location, and at a time that is convenient for you." No proctor, no test centre, no webcam staring at you.
It clears your mandatory CE for the year. "For the first year of the new model (2026) the Conduct Training will satisfy this requirement and will account for three hours of compliance credits."
An afternoon of free online training that discharges a regulatory obligation and your annual compliance CE at the same time is about as good as this industry's admin gets.
Before you enrol, have these ready
You enrol through the Enrolment Portal and take the course in the Candidate Portal — the same two portals the exam candidates use. Per CIRO's Mandatory Conduct Training Policy, enrolment asks you for three things:
- Your Approved Person category
- The name of your employing dealer
- The name and email address of your supervisor at the dealer
You also attest to being eligible. The policy is unusually sharp about getting that attestation wrong:
"Misrepresentation may lead to action by CIRO including; permanent ban from the enrolment site that prevents you from further being able to take CIRO exams or any other training provided in the future..."
A permanent ban from the enrolment site means a permanent ban from every future CIRO exam. Worth five seconds of care on a dropdown.
"I'm grandfathered" covers the exams only
A lot of people have filed this entire regime under doesn't apply to me, and on the exams they're right:
"If you were an existing Approved Person on December 31, 2025, you can continue in your current role without completing the new exams."
That relief is about exams. Conduct Training sits outside it and applies to all Approved Persons, grandfathered or otherwise. Being exempt from the CIRE and the other eight exams buys you nothing here.
One related thing worth knowing while you're thinking about your status: the exam exemption depends on staying in your role. A long enough break in approval brings the new requirements back into play, so if you're between firms or planning a move, check where you stand before you assume.
The short version
- December 31, 2026 for existing Approved Persons. 30 days from approval for new ones.
- Missing it is an automatic suspension, and the trigger includes the reporting, not just the training.
- Your dealer files it on NRD, and separately on CIRO Services-CE for the CE credit. Chase both.
- It's free, online, and covers your mandatory annual CE for 2026 at three compliance hours.
- Being grandfathered from the exams does nothing for this.
Enrol through the CIRO enrolment portal, block out an afternoon this month, and send the confirmation to your compliance team the same day. Then, in a week, ask them whether it's been filed. That last step is the one that keeps your registration.
Quotes in this post come from CIRO's Existing Approved Persons page, CIRO's Investment Dealers proficiency page, and the Mandatory Conduct Training Policy (v2, April 2026), all checked 13 October 2026. Deadlines move and policies get revised — confirm your own dates with your dealer.
