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CSA proposes to make the C$25 million listed-issuer financing limit permanent

Canadian regulators propose to write a 2025 blanket order into NI 45-106, keeping the prospectus-free financing limit at C$25 million, or C$50 million for larger issuers, after C$3.7 billion was raised under it in a year; comments close October 21, 2026.

The Canadian Securities Administrators, the umbrella body for the provincial securities regulators, published proposed amendments to National Instrument 45-106 on July 23, 2026 that would make permanent the higher limits on the listed issuer financing exemption, known as LIFE. The exemption, introduced in November 2022, lets an eligible exchange-listed company raise money from the public without a prospectus. A 2025 blanket order raised the ceiling "from a maximum of $10 million to $25 million – or up to $50 million" in a 12-month period, subject to conditions, and the CSA says that in its first year the order "facilitated $3.7 billion in capital raised," which it describes as "a pace of capital-raising eight times higher than what had occurred under the original, lower limits." The comment period runs 90 days and closes October 21, 2026 [1].

The release does not report how many issuers used the exemption or at what prices, only the total raised [1].

For a U.S. reader this is a supply-of-shares story. A cheaper, faster route to the public market means Canadian small and mid-cap companies will issue more equity, more often, and the C$3.7 billion figure says they already have [1]. The holder of an existing position bears the dilution whichever exemption the company relies on; the useful habit is to read each financing release for the price, the warrants and the fee, not for the name of the rule it cites.

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    CSA proposes to codify higher limits for listed issuer financing exemption after strong uptake Canadian Securities Administrators · July 23, 2026

    Vancouver; 'The CSA introduced the listed issuer financing exemption (LIFE) in November 2022 to offer a more efficient capital-raising option for eligible Canadian exchange-listed issuers'; proposed amendments to National Instrument 45-106 Prospectus Exemptions and its companion policy 'would primarily codify a 2025 blanket order that increased' the amount issuers can raise without a prospectus 'from a maximum of $10 million to $25 million – or up to $50 million' in a 12-month period, subject to conditions; 'In its first year, the 2025 blanket order facilitated $3.7 billion in capital raised', 'a pace of capital-raising eight times higher than what had occurred under the original, lower limits'; 'The 90-day comment period closes October 21, 2026'; quote from the CSA chair.

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