CSA Staff Notice 55-316 Questions and Answers on Insider Reporting and SEDI
4 Insider Information
4.3 Insider Report
Section 4.3.21

Do I Need To File A Report When I Become A Reporting Insider If I Do Not Own Or Control Any Securities Or Related Financial Instruments Of The Issuer?

Generally no. Please see the exemption in section 9.4 of NI 55-104.