CSA Access Model: Considerations for issuers

What is changing?

Under the new framework, non-investment fund reporting issuers can satisfy delivery requirements for certain continuous disclosure documents by making them electronically available through SEDAR+, rather than sending annual request forms and relying on traditional mail delivery processes.

The CSA has also noted that SEDAR+ will include notification functionality that allows investors to subscribe to receive email notifications when these continuous disclosure documents are filed.

The CSA has indicated that the model is designed to modernize issuer communications, increase the use of electronic delivery channels, and reduce the burden and costs associated with printing and mailing disclosure documents.

Beyond cost savings: The importance of disclosure management

While the Access Model is expected to reduce the need for certain print and mail activities, implementation involves more than simply moving documents online.

Issuers must meet specific filing, notification, website posting, and disclosure requirements within prescribed timelines. They must also provide advance notice when first adopting the model and include annual reminders regarding their electronic delivery practices.

Issuers considering adoption should evaluate whether the model is appropriate for their shareholder base and communication strategy, while also assessing any additional corporate law or regulatory delivery requirements that may continue to apply.

As a result, many issuers may benefit from reviewing their disclosure workflows to ensure they can efficiently manage the new requirements and maintain compliance throughout the reporting cycle.

How Computershare can help

The new framework creates an opportunity for issuers to take a more integrated approach to filing, disclosure management, and shareholder communications. Because the Access Model depends on timely SEDAR+ filing, investor notification, website coordination and continued fulfillment of investor requests, execution will matter as much as the decision to adopt it.

Computershare's e3 Filing solution can help issuers manage the filing component of this process with greater speed, accuracy and confidence. Our dedicated e3 team supports regulatory filings through SEDAR+, with attention to timing, document formatting, coding, accuracy and confirmation once the filing is complete.

What issuers should do next

With the anticipated September 2026 effective date approaching, issuers may wish to begin evaluating:

• Whether the Access Model aligns with their investor communication strategy
• Potential cost savings associated with reduced physical distribution
• Internal processes required to support news release and website posting obligations
• How filing and disclosure workflows may need to be updated
• The role of service providers in supporting adoption and ongoing compliance

As issuer communications continue to evolve, the CSA's Access Model represents another step toward digital-first disclosure delivery, offering issuers an opportunity to reduce administrative burden while maintaining investor access to critical financial information.

To discuss any changes to how you distribute certain continuous disclosure documents to shareholders, please contact Computershare or your Relationship Manager.

Computershare is not providing, and does not intend to provide, any legal, tax or investment advice.