On March 23, 2020, the Canadian Securities Administrators published local blanket orders for market participants that provide a 45-day extension for periodic filings normally required to be made by market participants on or before June 1, 2020.

As of April 21, 2020, our research indicates that at least 86 reporting issuers have announced their intention to rely on the exemption in order to delay a filing or delivery.

We note that among the issuers we identified, most are listed on the Toronto Stock Exchange, have a relatively small market capitalization (less than CAD$300 million for 94.2 % of the issuers), and operate in various industries.

The high percentage of TSX-listed issuers might be explained by the longer deadlines applicable to venture issuers, which allow, for example, venture issuers with a December 31 year-end to report annual results at the end of April (as opposed to the end of March for TSX-listed issuers). It will be interesting to see in the coming days and weeks if a significant number of venture issuers indicate their intention to rely on the exemption in advance of the upcoming filing deadline.

Issuers mostly relied on the exemption with respect to filing requirements, although we noted that one issuer with a market capitalization in excess of $1 billion used the exemption to make certain annual documents available electronically only until its printing supplier resumed its operations. Based on our research, we note the largest issuer to use the exemption so far had a market capitalization of approximately $4 billion.

Additional information regarding the blanket orders may be found in our blog post on the matter.