Joint CSA/IIROC Staff Notice 21-330 Guidance for Crypto-Trading Platforms: Requirements Relating to Advertising, Marketing and Social Media Use

The guidance addresses crypto-trading platforms that are subject to Canadian securities legislation because they trade securities or derivatives, or because a user’s contractual right relating to a crypto asset may itself be a security or derivative. Its principal audience is registered dealer platforms, platforms applying for dealer registration, and other registrants considering a crypto-trading platform as a business line.

The notice links marketing conduct to the broader registration framework. Canadian securities regulators may examine advertising during a registration review and after registration through compliance reviews. The notice also states that CSA members may pursue enforcement against non-compliant platforms, including foreign-based platforms with investors in Canada.

Staff Notice 21-330 focuses on statements that may be false or misleading. Examples include suggesting that a platform is registered when it is not, implying that a regulator has approved or endorsed the platform or its products, and omitting information needed to keep a material statement from being misleading. Registered platforms are also directed to consider duties to treat clients fairly, honestly and in good faith, together with know-your-client, know-your-product, suitability and conflict-of-interest obligations.

Appendix A illustrates the regulators’ concerns through claims about safety, regulatory status, exchange status, ratings, fees, pricing and execution. The notice emphasizes that broad promotional claims should be supportable, fair and balanced. A nearby disclaimer or assumption may clarify a statement, but the notice says disclaimers cannot rescue a claim that is itself false or misleading.

The regulators identify contests, bonuses, rewards and short time limits as potential investor-protection concerns when they are designed to create urgency or fear of missing out. Depending on the circumstances, such promotions may encourage excessively risky trading and may conflict with a registrant’s obligation to deal fairly, honestly and in good faith.

Marketing designed to generate trading may also amount to solicitation or an invitation to trade. That characterization can engage suitability obligations. A platform operating under relief conditioned on not making recommendations or providing advice must therefore consider whether active promotional messaging is consistent with the terms of that relief.

For business communications on social media, the notice highlights supervision, records and retrieval. Registered platforms must maintain required business and client records, including in environments that mix real-time and static content. The expected controls extend beyond official corporate accounts to communications by directors, officers, employees, shareholders and third parties acting for the platform.

The notice calls for policies and procedures covering review, approval, supervision, retention and retrieval of marketing materials. It also identifies the designation of a responsible reviewer and a system for monitoring compliance. A risk-based review of electronic communications may be used where it is sufficient to meet applicable supervisory obligations.

Staff Notice 21-330 is interpretive staff guidance rather than legislation. It should be read with the Canadian securities requirements and self-regulatory rules it discusses, including the broader platform guidance in Staff Notice 21-329. IIROC and the Mutual Fund Dealers Association amalgamated in 2023, and the resulting organization was named CIRO on June 1, 2023. CIRO now hosts the original notice without changing its 2021 title.

As of June 25, 2026, the notice remains available through CSA, OSC, ASC and CIRO resources. No separate effective date, expiry date or scheduled review is stated. Because it is staff guidance, its practical effect depends on the underlying securities legislation, registration conditions and self-regulatory rules that apply in a particular case. This profile describes the document and its regulatory context; it is not legal or compliance advice.