A practical CIRO marketing compliance checklist for wealth advisors

If you're a wealth advisor in Canada, every piece of marketing you produce falls under the oversight of the Canadian Investment Regulatory Organization. CIRO's Rule 3600 governs how advertising, sales literature, and correspondence are created, reviewed, and distributed. It isn't optional, and getting it wrong can result in enforcement action, fines, or reputational damage that takes years to repair.

But here's what often gets lost in the conversation: compliance doesn't have to be the thing that kills your marketing. With the right awareness and a practical CIRO marketing compliance checklist, you can produce compelling content that meets regulatory requirements without reading like a legal disclaimer.

Important note: This guide is not endorsed by CIRO and only provides general awareness of CIRO marketing requirements based on published information. It isn't legal advice and doesn't replace your firm's compliance review process. Always submit materials to your compliance team before publication.

Understanding the three CIRO content categories

CIRO classifies marketing content into three categories, and each carries different approval requirements. Advertising includes any promotional material distributed to the general public: your website, social media profiles, print ads, and public-facing brochures. These must be pre-approved by your dealer before first use.

Sales literature covers materials sent to specific clients or prospects, such as prospecting decks, emailed PDFs, and direct mail pieces. These also require pre-approval. Correspondence, meaning written communication to individual clients like emails and letters, must be supervised and retained, though pre-approval isn't always required unless it contains performance data or solicitation.

Knowing which category your content falls into is the first step toward getting it reviewed efficiently. When you submit something labelled correctly, your compliance team can process it faster.

The CIRO marketing compliance checklist: seven checks before you submit

Whether you're writing a LinkedIn post, updating your bio, or designing a prospecting brochure, running these checks before you send it to compliance will save you revision cycles and show that you take the process seriously.

1. Accuracy and fairness. Every factual claim must be verifiable. Benefits should be accompanied by relevant risks or limitations. Statistics need context: a timeframe, a benchmark, and a source. If a reasonable person could interpret your wording as misleading, revise it.

   
   

2. No performance promises. You can't guarantee, imply, or forecast specific investment returns. Language like "your portfolio will grow" or "guaranteed returns" isn't permissible. If you reference historical performance, include the required disclaimer: "Past performance doesn't guarantee future results."

   
   

3. Firm identification. All marketing materials must clearly identify your dealer. Your personal branding can't overshadow or replace the dealer's identity. Every brochure, one-pager, and social media profile should include the firm's name.

   
   

4. Credential accuracy. Every title and designation you list (CFA, CFP, CIM) must be current and correctly stated. Abbreviations should be spelled out at least once. Titles should reflect your actual role and registration.

   
   

5. Fee transparency. If you mention fees, they must be clear, complete, and not misleading. Claims like "low fees" need a comparison basis. Don't omit embedded costs such as MERs or transaction fees.

   
   

6. Balanced presentation. Content can't present only the positive attributes of a product or service. Risk factors shouldn't be buried or minimized. Comparisons to competitors must be fair and should never name competitors negatively.

   
   

7. Social media awareness. Social media posts are subject to the same rules as all other communications. Static content (bios, pinned posts) is treated as advertising and needs pre-approval. Interactive content (comments, replies) must be supervised. Your dealer's name should be identifiable on your profile, and business and personal accounts need to be clearly separated. We'll go into this as a separate topic in future.

Building compliance into your marketing workflow

The advisors who find compliance easiest are the ones who build it into their process from the start, rather than treating it as a final hurdle. That means thinking about CIRO requirements while you're drafting content, not after you've fallen in love with a headline.

A few practical habits that help:

• Keep a running list of your approved materials so you can reuse templates without re-submitting them.

• Write with the seven checks above in mind so your first submission is closer to approval-ready.

• Build a good relationship with your compliance team; they aren't the enemy of good marketing, they're the guardrail that keeps your marketing credible.

When we work with advisors on their marketing collateral, we apply these checks during the drafting process. Our content is compliance-friendly before it reaches the firm's review team, which tends to reduce revision cycles significantly. We covered the importance of building a consistent digital presence in an earlier post, and compliance awareness is a core part of that foundation.

Staying current with CIRO compliance requirements

CIRO publishes an Annual Compliance Report that highlights emerging areas of focus. The 2025 report placed particular emphasis on social media supervision (we'll review this in a future post), cybersecurity, and third-party vendor risk. These priorities shift over time, so it's worth reviewing the report each year to understand where regulators are looking most closely.

The regulatory environment is also actively evolving. CIRO's Rule Consolidation Project is harmonizing requirements across former IIROC and MFDA rules, which means some of the specifics may change. Staying connected to your compliance team and industry publications will help you adapt without scrambling.

Let us help you produce marketing materials that consider industry compliance from the first draft - we'd welcome the conversation.

Book a consultation to get started.