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OSC – Consultation on a Machine-Readable Regulatory Dataset
Letter Summary:
The OSC is seeking feedback on how best to build and shape a machine-readable dataset of Ontario’s securities regulatory framework. The initiative aims to facilitate access, reduce burden for capital markets participants, and support RegTech and compliance-automation solutions. The consultation page is organized around the OSC’s proposed approach, intended use cases, business requirements, and an example framework. This is a regulator-driven open-data initiative aligned with broader regulatory-burden and capital-markets-modernization themes.
Overview of the Council’s Comments
The CAC submitted comments to the Ontario Securities Commission on its consultation regarding a machine-readable regulatory dataset for Ontario securities legislation. The CAC supported the initiative and said it could reduce compliance costs, lower barriers for smaller firms and new entrants, and support regulatory technology that assists investors. The CAC’s central recommendation was that the dataset should be published as derivative, non-authoritative content that maps enacted law rather than replacing it. The CAC supported the OSC’s initiative and encouraged it to proceed promptly, stating that the recommended guardrails were intended to enable faster implementation while avoiding the legal and practical risks of presenting the dataset as the law itself.
Highlights by Theme
- Derivative, non-authoritative status: The CAC argued that the dataset should not be characterized as an authoritative statement of the law, because doing so could create legal and procedural complications and slow the project. It recommended clear operative language stating that enacted instruments prevail over the dataset in the event of inconsistency, with the dataset’s non-authoritative status also expressed in machine-readable form.
- Automated and AI-assisted use: The CAC noted that AI and automated compliance tools could produce inconsistent, probabilistic, or confidently incorrect outputs. It recommended that each record include machine-readable metadata on authority, currency, and provenance, and that users be able to rely on objective structure while excluding interpretive content.
- Legislative-data standards: The CAC questioned whether partial alignment with standards such as Akoma Ntoso and the European Legislation Identifier would meet the OSC’s interoperability goals. It recommended adopting a conformant application profile of an established standard, using persistent identifiers that survive re-processing, and reserving content hashes for integrity checks.
- Access, licensing, and correction: The CAC supported prioritizing reliable machine-readable information on whether instruments are in force and as of what date. It encouraged open and non-discriminatory licensing for the core dataset, disclosure of any commercial partner’s role, confirmation that the OSC owns resulting annotations and taxonomy, and a published correction process for reporting, assessing, versioning, and re-issuing fixes.