You have been approved for options since 2019. Your dealer circulates a note about CIRO's new proficiency model, there is a 120-question Derivatives Exam in it, and nowhere does it say whether that exam is yours.
Short answer: if you were approved before 1 January 2026 and you are still doing the same job, no. If your approval lapses for six months, yes — and that is the part the note almost certainly did not mention.
Quick facts: The exam is required for anyone seeking approval to deal in or supervise derivatives. Approved persons from before 2026 are exempt while they continue in the same role. "Same role" means your approval has not ceased for more than 180 days. The conduct training applies to everyone regardless.
What CIRO Actually Consolidated
Under the old model there were three separate derivative product proficiencies: options, futures contracts, and futures contract options. CIRO put them in one box.
"We have combined the product types of options, futures contract and futures contract options into one consolidated product type to capture all derivatives."
That is from CIRO's April 2025 guidance note on the proficiency model, which is where almost everything on this page comes from. One product type, one exam behind it: the Derivatives Exam, 120 questions in three hours.
The consequence for new approvals is blunt:
"An Approved Person who seeks approval to supervise or deal in any derivatives product must complete the Derivatives Exam."
Any derivatives product. There is no longer an options-only route and no futures-only route for someone coming in fresh.
If You Were Already Approved
Here is where the detail matters, and where it differs depending on which approvals you held.
Both options and futures
You are mapped across automatically. Per the guidance note, individuals currently approved to deal in both "can continue to do so in the new proficiency model as long as they continue in their role, and they will automatically be mapped over to the new product type of derivatives on NRD". Those continuing in the same role "are exempt from the new exam requirements, but they are still subject to complete the conduct training as prescribed under subsection 2604(2)".
So: no exam, new product type on your record, conduct training still due.
Options only, or futures only
You keep what you had, under a new name. Existing approved persons who trade in only one of the two "will be exempted into their existing categories" under subsection 2625(3), and the product type on NRD changes "from either options to options (legacy), or futures to futures (legacy)".
Then the sentence that decides it:
"These Approved Persons will not be required to take the new exams, including the Derivatives Exam unless they wish to deal in all derivatives, or, if they cease to be approved for a period of more than 180 days."
Two triggers, and both are worth sitting with.
You want to deal in all derivatives. The legacy category is a preservation of what you already do, not a stepping stone. CIRO is explicit that legacy holders "are not approved to deal in a single derivatives product type" and should keep their communications — including titles — clear about being restricted to one side. That obligation sits under section 3640, misleading communications. If a futures (legacy) representative starts taking option orders, the problem is not paperwork.
You stop being approved for more than 180 days. This is the one nobody mentions.
The 180-Day Rule
CIRO's test for whether you are "continuing in the same role" is mechanical:
"We will deem an individual to have continued in the same role as long as their approval did not cease for a period longer than 180 days."
Lapse for 180 days or fewer and return to the same role at a dealer, and your exemption from the post-2026 proficiency requirements survives. Pass 180 days and it does not:
"Individuals who cease to be approved and return after a period of more than 180 days will no longer be considered as continuing in the same role (to deal with the legacy options or futures) and will be subject to the new proficiency requirements, which includes a requirement to complete the Derivatives Exam."
Six months is not a long time in a career. A parental leave, a gap between firms, a sabbatical, a contract that ends in March and a start date in October — any of those can cross the line, and crossing it converts an exemption into a 120-question exam.
If your approval is going to lapse and you expect to come back to a derivatives role, the date your approval ceases is worth writing down. The rule does not care why the gap happened.
Coming in New
If you are applying rather than continuing, the requirements stack. For a Registered Representative dealing in derivatives, the guidance note lists:
- the applicable Retail Securities Exam and the Derivatives Exam
- the CIRE, unless you qualify for the FINRA exemption
- a relevant diploma or degree from an accredited post-secondary institution, or a minimum of four years of relevant experience acceptable to CIRO
- any outstanding post-approval requirements
At $475 a sitting that is $1,425 in exam fees before tax for CIRE plus RSE plus Derivatives — the full price list for all nine exams is in our CIRO exam fees breakdown, and the decision map for which exams your role needs is in Which CIRO Exam Do I Need?
The FINRA and NFA Route
There is a specific exemption from the Derivatives Exam, and it is narrower than people assume. Under subsection 2627(2), an individual applying as an RR, an Investment Representative, or a Supervisor over those individuals is exempt if they were:
- "previously registered and dealing in options and futures with FINRA and the NFA within three years prior to the application for approval", and
- have "completed the Series 3 and Series 7 exams offered by FINRA"
Both conditions, not either. And CIRO adds a practical gloss: while no minimum period is written into the rules, "experience dealing with options should be meaningful", and registration staff "will look for a minimum of 12 months of experience dealing in options and futures contract and futures contract options", assessed case by case.
A separate provision exempts FINRA registrants from the CIRE on similar terms.
What the Old Courses Are Worth Now
The Derivatives Fundamentals and Options Licensing course, the Options Licensing Course and the Futures Licensing Course were the old path. They are not the new one. CSI's own course pages state that from 1 January 2026 the proficiency rules for investment-dealer approved persons changed, and that the Futures Licensing Course "is no longer acceptable for the purposes of CIRO approval with an Investment Dealer".
If you enrolled before 1 January 2026 and are part-way through, there is a transition provision — the same one that covers the Canadian Securities Course. It has conditions on completion dates and on your sponsoring dealer filing in time, and the dealer's filing deadline is the one most often missed. Talk to your firm's compliance team before you assume a course in progress still gets you there.
One Thing Everybody Owes
The exam exemption is not a general exemption. Every path above — both-products, options-legacy, futures-legacy, continuing in the same role — carries the same footnote: the conduct training under subsection 2604(2) still applies.
If your firm has told you that you are grandfathered, that is probably true about the exam. It is not true about the training. We have written up the deadline and what it covers in CIRO's conduct training deadline.
If You Do Need It
Start with the free Derivatives readiness check — 25 questions weighted like the real blueprint, scored element by element, about fifteen minutes, no signup. It is the cheapest way to find out how much of the 120 questions you already own from the desk.
Then: the syllabus, element by element, whether it is hard, and an eight-week plan. The full prep is at EnCiro Derivatives — 10,000+ scenario-based questions, 275+ learning-centre concepts each with a narrated episode, and custom mocks you can aim at a single element.
One caveat worth stating plainly: everything above is CIRO's published guidance and the rules it cites, not advice about your file. Registration categories are confirmed by your sponsoring dealer, and your firm's compliance team can tell you in one email which category you are in and what it owes. Ask them before you pay for anything.
FAQ
Do I need the CIRO Derivatives Exam?
You need it if you are seeking approval to deal in or supervise derivatives and you were not already approved before 1 January 2026. If you were approved before that date and you continue in the same role, you are not subject to the new proficiency requirements — but you still have to complete CIRO's mandatory conduct training, and the exemption depends on your approval not lapsing for more than 180 days.
I'm approved for options only. Do I have to write the Derivatives Exam?
No, as long as you continue in that role. CIRO moved approved persons who deal only in options, or only in futures, into new options (legacy) and futures (legacy) product types on NRD. Per CIRO's guidance, those individuals will not be required to take the new exams, including the Derivatives Exam, unless they wish to deal in all derivatives or their approval ceases for more than 180 days.
I'm approved for both options and futures. What happens to me?
You are automatically mapped to the new consolidated derivatives product type on NRD, and you are exempt from the new exam requirements while you continue in the same role. The conduct training under subsection 2604(2) still applies to you.
What is the 180-day rule?
CIRO deems you to have continued in the same role as long as your approval has not ceased for longer than 180 days. Lapse for 180 days or less and return to the same role, and your exemption survives. Pass 180 days and you are no longer continuing in the same role — you become subject to the proficiency requirements in force from 1 January 2026, which for a derivatives role includes the Derivatives Exam.
Can FINRA or NFA registration exempt me from the Derivatives Exam?
Yes, under subsection 2627(2). An applicant for RR, IR or Supervisor dealing in derivatives is exempt if they were previously registered and dealing in options and futures with FINRA and the NFA within three years prior to the application, and completed the Series 3 and Series 7 exams. CIRO's registration staff look for a minimum of about 12 months of that experience as a guideline, assessed case by case.
Do the old DFOL, OLC and FLC courses still work?
Not as a path to new CIRO approval at an investment dealer. CSI states that from 1 January 2026 the proficiency rules for investment-dealer approved persons changed and that the Futures Licensing Course is no longer acceptable for CIRO approval with an investment dealer. A pre-2026 enrolment may still be recognised under the transition provision if the course and its exams are completed in time and a sponsoring dealer files before the deadline — confirm with your firm before relying on it.
Does the exemption mean I never have to do anything?
No. Every existing approved person is still required to complete CIRO's new mandatory conduct training under subsection 2604(2). The exam exemption and the conduct training are separate obligations, and the second one applies to everyone.
Sources
- CIRO — Guidance Note, Proficiency Model for Approved Persons of Investment Dealers (17 April 2025) — the consolidation of the three derivative product types, the options (legacy) and futures (legacy) categories, the 180-day test for continuing in the same role, the FINRA/NFA exemption under subsection 2627(2), and the conduct training obligation under subsection 2604(2). Hosted by the British Columbia Securities Commission
- CIRO — Existing Approved Persons — how the transition applies to people already approved
- CIRO — Proficiency for New Candidates — the requirements for new approvals, enrolment and fees
- CIRO — Derivatives Exam — the syllabus, study guide and practice exam
