Over the past year, Canada’s federal and provincial governments have accelerated efforts to dismantle interprovincial labour‑mobility barriers. A key focus is enabling certified professionals, such as insurance advisors, which include agents, brokers and adjusters, to practice across provinces with fewer administrative hurdles. Currently, provincial licensing requirements are not harmonized, requiring advisors to navigate fragmented licensing regimes that often involve additional exams, varying education standards and compliance obligations and cumbersome paperwork, when serving clients outside their home province.
In 2025, federal and provincial leaders committed to streamlining credential recognition. Canada’s Prime Minister and Premiers endorsed a 30‑day service standard for cross‑country recognition, and several provinces entered into mutual recognition agreements to expedite licensing. Ontario emerged as a leader through its “As of Right” initiative, which temporarily treats out‑of‑province credentials of in‑demand regulated professions, including insurance advisors, as equivalent to Ontario credentials, in order to reduce delays and foster a more unified national workforce.
This article focuses on Ontario, examining its legislative changes and the corresponding implementation by its insurance regulators—the Financial Services Regulatory Authority (“FSRA”) and the Registered Insurance Brokers of Ontario (“RIBO”)—effective January 1, 2026, and explaining how these measures are intended to enable more efficient cross‑border practice for insurance agents, brokers and adjusters.
Legislative Changes Enabling Labour Mobility
In June 2025, Ontario introduced sweeping reforms to dismantle provincial licensing barriers through Bill 2, Protect Ontario Through Free Trade Within Canada Act, 2025. This legislation amended the Ontario Labour Mobility Act, 2009, creating an “As of Right” regime and enacted the Ontario Free Trade and Mobility Act, 2025.
The “As of Right" Regime
The “As of Right” regime created by the amendments to the Ontario Labour Mobility Act, 2009 applies to individuals (natural persons) already certified in a regulated occupation by an out-of-province authority may be deemed certified in Ontario for a one-time six-month period, provided they meet prescribed requirements.
Key features of the “As of Right Regime” include:
- Expedited Timelines: Ontario regulators must acknowledge receipt of an application within 10 business days and issue a certification decision within 30 calendar days of receiving a complete application. Failure to meet these standards could result in compliance orders against the regulator – a notable instance of holding a regulator to account through statutory deadlines.
- Reduced Barriers: Regulators are prohibited from requiring substantial additional training, experience, examinations, or assessments for out-of-province professionals, except in narrow circumstances justified in the public interest.. Allowed exceptions might include a reasonable requirement to complete a criminal record check or obtain errors & omissions insurance.
- Transparency: Regulatory authorities must publish all imposed conditions and requirements on a publicly accessible website.
- Penalties for False Claims: To prevent abuse of the deemed certification regime, making false representations is now an offence. Any person who knowingly misrepresents their qualifications for deemed certification faces fines up to $25,000 for a first offence and up to $50,000 for subsequent offences.
To operationalize these changes, on September 1, 2025, Ontario filed O. Reg. 199/25: Deemed Certification under the Ontario Labour Mobility Act, 2009. Effective January 1, 2026, the Deemed Certification Regulations prescribe that insurance agents, brokers and adjusters, among others, are covered by the new mobility rules. The regulations allow Ontario’s licensing bodies to perform reasonable checks on incoming applicants (e.g. attestations of good standing, malpractice insurance, sponsorship by an Ontario licensee, criminal record checks) and prohibit imposing onerous new exams or training on experienced out-of-province professionals.
Mutual Recognition Framework
In late December 2025, Ontario also launched a consultation process on the proposed mutual recognition framework under the Ontario Free Trade and Mobility Act, 2025, and the proposed regulation(s). The intention of the proposed regulatory framework is to designate reciprocating jurisdictions from which Ontario would recognize, among others, out-of-province authorizations (including certificates, licences and registrations) issued to a person or entity (but not including natural persons, which are subject to the “As of Right” regime), as being equivalent to authorizations issued in Ontario. Notably, Ontario suggested that the proposed mutual recognition framework would help reduce red tape and the regulatory burden associated with doing business and working in multiple Canadian jurisdictions without necessarily needing to undertake processes for harmonizing different regulatory requirements within multiple regulated sectors.
Key features of the proposed mutual recognition framework include:
- Designation of Reciprocating Jurisdictions: The draft regulation, currently under consultation, proposes to designate Canada, British Columbia, Manitoba, Nova Scotia, Prince Edward Island, and Quebec as the initial reciprocating jurisdictions. Additional jurisdictions may be designated in the future once they have made sufficient progress in developing their own mutual recognition frameworks.
- Regulators Authority: Similar to the “As of Right” model, Ontario regulators may request limited additional information from out-of-province service providers (e.g., proof of insurance, criminal record checks, evidence of good standing) to ensure compliance with Ontario laws and regulations once authorization is granted. Regulators may refuse authorization where necessary to protect the public interest, including where complaints or criminal, disciplinary, insolvency, or other proceedings exist in any jurisdiction.
- Temporary Suspension: The proposed mutual recognition framework contemplates granting Ontario regulators authority to temporarily suspend mutual recognition for a period not exceeding 90 days, in cases that pose demonstrable and serious risk to Ontarians.
The consultation period is open until January 28, 2026.
How Ontario’s Insurance Regulators Implemented the “As of Right” Regime
Legislation is only half the story – putting the new mobility rights into practice for the insurance industry fell to Ontario’s insurance regulators. Two bodies oversee insurance advisors in Ontario:
- FSRA – regulates insurance agents (life, accident & sickness, and property & casualty agents who represent insurers), as well as insurance adjusters.
- RIBO – the self-regulatory body for insurance brokers (independent agents who represent consumers and multiple insurers in the P&C market).
Both FSRA and RIBO took steps to roll out Ontario’s new “As-of-Right” labor mobility regime for their licensees. On December 31, 2025, FSRA announced that beginning January 1, 2026 it would introduce an “express lane” licensing process for out-of-province agents and adjusters. On January 5, 2026, RIBO announced the launch of a Temporary Labour Mobility Licence program for property and casualty insurance brokers from other provinces. The implementation by FSRA and RIBO of the “As of Right” licensing process effectively follows the requirements set out in the amended Ontario Labour Mobility Act, 2009 and the Deemed Certification Regulations.
Some of the key features of the “As of Right” licensing process include:
- Eligibility and Licensing Requirements: The process is designed for non-Ontario residents who hold a valid insurance intermediary licence in another Canadian jurisdiction. Out-of-province applicants must meet specific requirements, including:
- Providing a letter from their home regulator verifying an equivalent licence in another province or territory;
- Disclosing any licence conditions;
- Submitting a recent criminal record check;
- Attesting to good standing—confirming no ongoing investigation by their home regulator, recent licensing refusals, disciplinary or misconduct findings, or criminal offences;
- For insurance agents and adjusters applying to FSRA, applicants must be sponsored by a licensed insurer in Ontario and complete the Ontario Auto Equivalency exam (FSRA suggests completing this exam before applying under the “As of Right” labour mobility process, as otherwise the applicant will have to complete it within 10 business days after submitting the application);
- For insurance brokers applying to RIBO, applicants must have a job offer from an Ontario-licensed brokerage, and there must be a designated Principal Broker responsible for their supervision.
- Licensing Term and Scope: Once the application is submitted, FSRA and RIBO must confirm receipt within 10 business days. Upon the notice of receipt from the regulator, the applicant is immediately deemed licensed in Ontario for a one-time six-month period. During this period, the incoming advisor must abide by all Ontario laws and regulatory requirements, including professional obligations. In practice, they have the same authority and obligations as any Ontario licensee. For insurance brokers, the temporary licensee cannot act as a Principal Broker or open their own brokerage; the licence is strictly for working in an existing brokerage.
- Full Licence Requirement: The temporary licensee has six months to complete any remaining steps for full Ontario licensing. This typically includes filling out standard application forms, providing supporting documentation, paying fees, and (if applicable) passing an equivalency exam. Once a complete application for full licensure is submitted, FSRA and RIBO has a legislated deadline – 30 calendar days – to review and make a final licensing decision. This 30-day clock starts only when a complete application is filed. If the advisor obtains a full licence early, the temporary licence terminates; if they fail to qualify, the temporary licence is cancelled and cannot be reinstated. If FSRA or RIBO plans to deny or attach conditions to the Ontario licence, they must explain their reasons in writing and provide information on how to appeal or challenge the decision.
Conclusion
The introduction of Ontario’s new labour mobility requirements under the “As of Right Regime” for insurance advisors marks a positive step toward a more integrated Canadian insurance market, one in which credentials follow professionals across provincial lines. Where once out-of-province individual insurance advisors faced duplicative licensing processes, the “As of Right” Regime now offers a near-automatic bridge licence to get them working quickly, setting a precedent for other provinces and taking the first step toward a future where an insurance licence is portable across Canada.
Ontario’s ongoing consultation on a mutual recognition framework reflects an even broader ambition: a unified labour market where credentials follow licensed businesses across jurisdictions. While Ontario does not appear to view harmonization of regulatory regimes as the primary path forward, the proposed mutual recognition framework—if adopted nationally—could provide an efficient mechanism for reducing regulatory barriers and lowering compliance costs for businesses operating across Canada.
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