Subsequent to a review of compliance with MI 52-109 Certification of Disclosure in Issuers' Annual Interim Filings (now replaced by NI 52-109) , the CSA have published CSA Staff Notice 52-315. The Staff Notice outlines the review's results and "provides guidance to issuers and certifying officers in complying with the certification requirements." The review focused on two aspects of compliance: (i) whether the correct form of certificate was filed; and (ii) whether an issuer's annual MD&A contained disclosure regarding the certifying officers' conclusions with respect to the effectiveness of disclosure controls and procedures.

While the CSA found that most issuers filed the correct form of certificate, 28% of issuers sampled failed to include disclosure in annual MD&A regarding the effectiveness of disclosure controls and procedures. Compliance with this requirement was found to be higher with TSX Issuers (80% compliance) than with Venture Issuers (38% compliance) or CNQ Issuers (40% compliance).

The CSA noted that "a significant percentage" of issuers did not comply with certification requirements and stated that it will actively follow up on identified deficiencies.