Earlier today, the OSC issued the much anticipated (maybe a bit of an exaggeration!) 2026 Risk Assessment Questionnaire (“RAQ”). The RAQ is typically issued every two years and is used to help gather additional information on the firms registered with the OSC.
This data may be used to help inform future regulatory policy making (e.g., whether to issue a staff notice to provide guidance for a common area of deficiency). However, as the name suggests, it is principally part of the OSC’s risk assessment model in selecting firms for compliance reviews.
As identified in the advanced notice sent on April 1st, the 2026 RAQ is substantially similar in scope to the 2024 RAQ. However, there are still some changes that are worth noting:
· Conflicts of Interest – As part of the General Section, a registered firm is now required to select all the categories of material conflicts of interest it has identified since December 31, 2025. This is not particularly surprising, given that compliance with the enhanced conflict of interest requirements (introduced by the Client Focused Reforms) has been previously flagged by OSC staff as being an area of common deficiency among all registration categories.
· Chief Compliance Officer (“CCO”) Certification – Unlike in prior years where the firm’s ultimate designated person was required to certify that they reviewed the responses, this year this responsibility will rest with the CCO.
· No References to AI – Perhaps one notable omission is the lack of any questions relating to the use of artificial intelligence (“AI”). AI was identified by OSC staff as being part of the 2025-2026 examination priorities and the CSA has previously issued guidance on the use of AI by registrants in December 2024.
For any registrant that might be looking for additional guidance on completing the 2026 RAQ, OSC staff will be hosting a webinar on May 14th to highlight key changes and answer frequently asked questions.