August 22, 2025
PDAC Response to the Government of Canada's Consultation on the Free Trade and Labour Mobility in Canada Act
PDAC supports the Act’s goal of reducing federal barriers to the movement of goods and services in Canada. This objective in mind, we are concerned about a proposed change from the Canadian Securities Administrators (CSA) to National Instrument 43-101 (NI 43-101) that would require provincially designated professionals to acquire an additional 5 years of experience before they can act as a Qualified Person for federal disclosures. PDAC recommends that the Act be applied to ensure that no 5-year waiting period is imposed on accredited professionals and to recognize the authority of governing provincial and territorial associations in determining who may act as a qualified person.