Canada has no legal definition of “fee-only.” We found no federal or provincial rule that defines it, and as planner Jason Heath wrote in MoneySense in 2020, “there is no regulatory reason someone cannot call themselves fee-only.” What Canadian regulators do define is registration: who may trade or give specific advice on securities, which firms belong to CIRO, and, in Ontario and Quebec, who may call themselves a financial planner. So a Canadian planner proves fee-only status by what they don’t have: no dealer, no commissions, no trailing commissions, no referral fees. In Wellspent’s October 28, 2026 check, 20 of 206 Canadian listings named a dealer tie in their own published material, about 1 in 10.
This guide explains the pieces and what to publish so clients and AI assistants read you correctly. For pricing and practice as an advice-only planner, see Advice-only planning in Canada.
Who regulates what
Canada splits the job among several bodies, and none of them is in charge of “fee-only.”
| Body | What it controls | What it means for a fee-only planner |
|---|---|---|
| Provincial securities commissions (the CSA) | Registration of dealers and advisers under NI 31-103 | Giving specific advice on securities requires registration |
| CIRO | Investment dealers and mutual fund dealers | Being a dealing representative ties you to a dealer |
| FSRA (Ontario) | The Financial Planner and Financial Advisor titles | You need an approved credential to use them |
| AMF (Quebec) | Securities, insurance and the financial planner title | A certificate is required to use the title or offer planning services |
| FP Canada | CFP and QAFP certification | Approved in Ontario as Financial Planner credentials |
CIRO is the newest piece. The two old self-regulatory organizations, IIROC for investment dealers and the MFDA for mutual fund dealers, combined and began operating as one on January 1, 2023, and took the name Canadian Investment Regulatory Organization on June 1, 2023.
What fee-only means in practice
Because the law is silent, the working definition comes from how a planner is paid. A fee-only planner is paid only by the client. That rules out:
- Commissions on funds, securities or insurance.
- Trailing commissions, the ongoing payments built into many mutual funds.
- Referral fees from anyone you send a client to.
- A dealer affiliation. A dealing representative works for an investment dealer or mutual fund dealer, the Canadian counterpart of a US broker. Even when the advisor charges a fee, often sold as “fee-based,” the dealer can earn from the products it sells, so the advice and the products come from the same place.
Most Canadian fee-only practices take one of three shapes:
- Advice-only planning. The planner charges for plans or hourly work and doesn’t hold or manage investments. The OSC’s companion policy to NI 31-103 says registration as an adviser applies to “specific advice,” which it defines as advice “tailored to the needs and circumstances of a client,” such as recommending a security. Planners who stop short of that generally aren’t registered, and rely on their credential instead.
- A portfolio manager charging a fee. A firm registered as a portfolio manager with a securities commission, with no dealer and no commissions, charging a percentage of assets or a flat fee. This is fee-only by pay, and registered to give specific advice.
- A planner who is also licensed to sell insurance. Fee-only only if no commissions are taken. A planner who earns insurance commissions isn’t fee-only, whatever the website says.
Planner titles: Ontario and Quebec
Two provinces control who can call themselves a planner. Neither rule says anything about how the planner is paid.
Ontario. The Financial Professionals Title Protection Act came into force on March 28, 2022. Anyone using the title Financial Planner or Financial Advisor needs a credential from a credentialing body approved by FSRA. FP Canada was approved on April 11, 2022, and the CFP and QAFP are approved Financial Planner credentials, though not Financial Advisor credentials. People who used a title before January 1, 2020 had transition periods, which ended March 28, 2024 for Financial Advisor and March 28, 2026 for Financial Planner.
Quebec. The title “financial planner” (F.Pl.) requires a diploma from the Institut de planification financière and a certificate from the AMF, and the AMF says no one may use the title or offer financial planning services in Quebec without the appropriate certificate.
Elsewhere. Saskatchewan passed a similar law, the Financial Planners and Financial Advisors Act, in July 2020, and New Brunswick consulted on one in 2021. We couldn’t confirm from the regulators’ current pages whether Saskatchewan’s law is now in force, so check with the FCAA before relying on it. We found no title rule in the other provinces.
How Wellspent checks Canadian firms
In the US, Wellspent confirms fee-only status from SEC filings. Canada has no public filing like Form ADV that states how a planner is paid, so the check reads what each firm publishes about itself. We look for:
- a dealer in the firm’s name,
- a website on a dealer’s domain,
- a dealer named next to the firm’s CIPF or CIRO disclosure, the notices CIRO dealer firms carry,
- an advisor title tied to a dealer, or wording like “through our mutual fund dealer.”
Each finding keeps the exact quote it rests on. A firm with a dealer tie leaves fee-only lists and matching, and its page in the public graph shows a “Dealer” fact. In the October 28, 2026 run, 20 of 206 Canadian firms showed a tie, all but one to an investment dealer. We rerun the check after each website refresh.
The check can only read what you publish. If your website still carries a CIPF notice or an old dealer’s name from before you went independent, you’ll read as dealer-affiliated.
What to publish so you read as fee-only
AI assistants lean on outside sources more in Canada than in the US. In our study of 600 AI answers, only 20% of Canadian answers cited a firm’s own website, against 87% in the US, and the public graph was cited in 39% of Canadian answers, as often as MoneySense. So say it plainly on your site and make every outside page agree:
- How you’re paid, in one sentence. “We’re paid only by our clients. We receive no commissions, trailing commissions or referral fees.”
- What you’re not. “We are not affiliated with any investment dealer or mutual fund dealer.”
- Your registration, or why you have none. Name your portfolio manager registration, or say you give planning advice and don’t recommend specific securities.
- Your credential, and, in Ontario, the title you’re entitled to use.
- Your prices. Canadian fee-only firms that publish prices charge a median C$1,900 for a one-time plan, C$250 an hour and C$2,300 a year for ongoing planning (Wellspent fee report).
- Clean up the past. Remove old dealer logos, CIPF notices and dealer email addresses.
Source: Wellspent fee report and Canadian fee-only check, October 2026
How clients check you
Tell clients where to look; it shows you expect to be checked. The CSA’s National Registration Search shows who is registered to trade or advise in securities, and in what category. CIRO’s AdvisorReport covers advisors at CIRO dealer firms, with qualifications and discipline. FP Canada’s Find a Planner confirms CFP and QAFP certification. A fee-only advice-only planner may appear only in the last one, which is why your own words about pay matter so much.
For where Canadian planners are listed and how each source checks them, see FP Canada vs Globe and Mail Find an Advisor vs Wellspent.
Where Wellspent fits
A Wellspent record states how you’re paid, your fees, specialties, credentials and the clients you serve, with sources, in the public graph Canadian AI answers already cite. Canadian fee-only and advice-only planners qualify; firms with a dealer tie are left out of fee-only lists. Membership is $89 a month, billed in US dollars, and includes introductions from prospects with no lead fees, a monthly report on who AI assistants recommend, and quarterly press placement with media partners. See How it works.