On December 18, 2025, the Government of British Columbia announced the long-awaited Restricted Insurance Agent Licence Regulation (“Regulation”), which will come into force on January 1, 2027, alongside certain provisions of the Financial Institutions Amendment Act, 2019. The Regulation will require certain non-insurance businesses that sell insurance products incidental to consumer goods and services to obtain a Restricted Insurance Agency (“RIA”) licence from the Insurance Council of British Columbia (“ICBC”). The Regulation includes transitional provisions that will allow certain businesses and individuals currently exempt from licensing to continue operating under those exemptions for a limited period after January 1, 2027.
The new RIA regime is substantially similar to those already in effect in four other provinces—Alberta, Saskatchewan, Manitoba, and New Brunswick (“Other RIA Jurisdictions”)—but contains notable differences regarding the scope of eligible businesses and the types of optional insurance they may sell incidentally to their primary business.
The Regulation was developed after an extensive consultation process that began in 2022, as further described in our 2022 post “British Columbia Conducts Consultation on Restricted Licence Regime for Incidental Sellers of Insurance”. ICBC will conduct a public consultation beginning in February 2026 to develop detailed licensing rules, competencies, and the oversight framework that will govern the RIA regime.
What is an RIA Licence
According to section 174.1(2) of the Financial Institutions Act, which, like the Regulation, comes into force on January 1, 2027:
A restricted insurance agent licence authorizes the licensee, through the licensee’s employees and agents in British Columbia, to act or offer to act as an insurance agent in respect of one or more prescribed classes of insurance that are specified in the licence.
The Regulation clarifies that an RIA may act as an insurance agent only in respect of optional insurance that is incidental to its ordinary business. It identifies the following businesses as eligible to obtain an RIA licence, permitting their employees and agents to sell the corresponding classes of insurance products:
Similar to Manitoba and New Brunswick, the RIA regime in British Columbia expressly authorizes a licence holder to act through both its employees and its agents. By comparison, Alberta and Saskatchewan limit such authority in their legislation and regulation to the licensee and its employees.
The Regulation does not specify licensing or competency requirements, nor does it set out oversight provisions for the RIA regime, as these matters will be addressed through a public consultation conducted by ICBC. However, the Regulation does require that each RIA licensee appoint a designated individual, approved by ICBC, to serve as the licensee’s primary contact—a requirement that is also found in other RIA jurisdictions.
How the B.C. RIA Regime Compares to Others
The RIA regime in British Columbia is substantially similar to the RIA regimes in Other RIA Jurisdictions. The Regulation includes an extensive set of definitions that clarify the scope of the affected types of business and optional insurance they can sell incidentally to their primary business. Many of the definitions and the scope of the RIA regime are the same as those found in Other RIA Jurisdictions, but there are some notable differences, which we discuss below.
Credit Protection Insurance
Credit protection insurance is defined as “insurance effected by a creditor under which an insurer undertakes to pay to the creditor the credit balances or debts of a debtor, in whole or in part, in the event of an impairment or potential impairment in an individual’s income or ability to earn an income.” A notable aspect of this definition is the requirement that insurance be “effected by a creditor.” This requirement aligns with the concept of group creditor insurance under sections 37 and 92 of the Insurance Act (British Columbia), which similarly contemplates insurance being arranged by the creditor. The British Columbia Financial Institutions Commission (BCFICOM) addressed this issue extensively during its 2015 industry consultation, as reflected in Bulletin INS‑15‑002, underscoring the policy rationale for maintaining this limitation. However, the “effected by a creditor” requirement is not found in the sister definitions of “credit protection insurance” in the Classes of Insurance Regulation (British Columbia) or in Other RIA Jurisdictions, where definitions are generally broader and do not impose this structural limitation. While the Regulation identifies credit grantors – defined as “a person, other than a financial institution, extraprovincial corporation, bank or federal credit union, who offers, arranges, provides or facilitates credit” – as an eligible class of persons to sell credit protection insurance, such insurance, based on its statutory definition, must still be “effected by a creditor”, consistent with the group creditor insurance framework in the Insurance Act (British Columbia).
Another distinction is that the Regulation uses an umbrella definition tied to impairment of income or earning ability, whereas Other RIA Jurisdictions provide more granular definitions for creditor’s life, disability, loss-of-employment, and vehicle inventory insurance, which are substantively aligned with the Regulation’s broader concept.
Guaranteed Asset Protection Insurance
Guaranteed asset protection insurance is defined as “insurance (a) that is within the class of property insurance or automobile insurance, as those classes are defined in section 1 (1) of the Classes of Insurance Regulation, B.C. Reg. 204/2011, and (b) that provides coverage to an owner or lessee of a vehicle or equipment, in the event of the unrecovered theft of the vehicle or equipment or its total loss, for some or all of the amount owed on the purchase financing for the vehicle or equipment or on the lease agreement, after credit for money received in respect of the theft or loss from any other insurance under which the owner or lessee has coverage for the vehicle's or equipment's value.” While this definition is largely consistent with those in Other RIA Jurisdictions, Alberta classifies guaranteed asset protection insurance as property insurance only, and Saskatchewan treats it as automobile insurance.
Funeral Expense Insurance
Unlike Saskatchewan, Manitoba, and New Brunswick, the Regulation does not set monetary limits on funeral services that can be provided under funeral expense insurance. This approach is consistent with Alberta’s RIA regime. Saskatchewan, Manitoba, and New Brunswick set $25,000, $15,000, and $20,000 monetary limits, respectively, for funeral services covered under funeral expense insurance.
Portable Electronics Insurance
The Regulation identifies portable electronics vendors as an eligible business class for an RIA licence and allows them to sell portable electronics insurance. It also provides definitions for “portable electronic vendor,” “portable electronics insurance," and “portable electronic device,” with the latter being notably granular, enumerating various device types and accessories.
Saskatchewan’s and Manitoba’s RIA legislation also identify portable electronics vendors as eligible for RIA licensing and provide definitions for “portable electronic vendor” and “portable electronics insurance.” However, neither province prescribes a detailed definition of “portable electronic device” in their respective insurance legislation. Saskatchewan’s regulator offers interpretive guidance in its regulatory bulletin, which is substantially similar to the Regulation’s definition but less formalized in legislative text. In New Brunswick, the insurance legislation provides detailed definitions for “portable electronic vendor,” “portable electronics insurance," and “portable electronic device,” which are substantially similar to the Regulation. However, New Brunswick notably exempts portable electronics vendors from licensing requirements, provided they meet prescribed disclosure requirements. Alberta does not identify portable electronic vendors as an eligible class for RIA licensing, and portable electronics insurance is not a specific class of insurance defined in provincial legislation.
Rented Vehicle Insurance
Similar to the “credit protection insurance” definition, “rented vehicle insurance” is a single defined term in the Regulation that covers injury/death and medical expense reimbursement, contents, and liability related to a rented vehicle. In Saskatchewan, Manitoba, and New Brunswick, there are three distinct types of rented vehicle insurance (i.e., rented vehicle accidental injury or death insurance, rented vehicle contents insurance, and rented vehicle liability insurance). Alberta takes a different approach and classifies rented vehicle coverage under personal accident insurance and personal effects coverage. Despite these differences, the scope of coverage is largely consistent between the Regulation and Other RIA Jurisdictions.
The Regulation identifies vehicle rental agencies and travel agents/wholesalers as eligible classes to sell rented vehicle insurance. Other RIA Jurisdictions do not explicitly identify travel agencies as eligible to sell rented vehicle insurance, although in New Brunswick, travel insurance includes coverage for loss incurred from rental of a motor vehicle while on a trip. Additionally, the Regulation introduces “peer-to-peer vehicle service providers” as an eligible class for rented vehicle insurance—a category unique to British Columbia. Peer-to-peer service providers are defined as persons who, through an online platform, connect vehicle owners with renters (without a driver) for periods of less than one month.
Travel Insurance
The definition of “travel insurance" in the Regulation is largely the same as in Other RIA Jurisdictions, except in Manitoba, where the insurance legislation divides travel insurance into "personal travel insurance" (life and/or accident and sickness insurance) and "travel interruption and property-loss insurance" (property insurance).
The most notable distinction is that the Regulation does not include deposit-taking institutions or trust companies as eligible classes of persons allowed to sell travel insurance, whereas Other RIA Jurisdictions do.
Warranty Insurance
Unlike Other RIA Jurisdictions, the Regulation separates warranty insurance by asset class (construction equipment, farm implements, pleasure craft, vehicles). Alberta and Saskatchewan have a subclass of equipment warranty insurance, but it is not asset-specific. Manitoba and New Brunswick do not have a comparable classification.
Interested readers should refer to sections 1 through 4 of the Regulation for the full definitions and the scope of the Regulation.
Implementation
ICBC is implementing the new RIA licensing regime through a staged rule-making and consultation process. Public consultation on proposed rules begins in February 2026, followed by finalization later in 2026 ahead of the Regulation coming into force on January 1, 2027, subject to a transition period for certain businesses and individuals.
The Regulation sets out transitional rules for certain businesses and individuals previously exempt under the Insurance Licensing Exemptions Regulation (British Columbia). These include motor vehicle dealers, travel agents and wholesalers, funeral providers, mortgage brokers, credit grantors, deposit-taking institutions, and their commissioned sales representatives or employees. After the Regulation comes into force on January 1, 2027, these exemptions continue temporarily while the business applies for an RIA licence. For most businesses, the exemption ends on the earlier of March 31, 2027 if no application is filed, 30 days after an application is refused, or 90 days after a licence is issued. The only difference for travel agents and travel wholesalers is that the Regulation does not impose the March 31, 2027 deadline; instead, their exemption continues until one of the other conditions occurs—either the licence is issued or the application is refused. This transition rule provides the travel industry with additional flexibility to adjust to the new RIA regime.
Next Steps
Stakeholders may wish to monitor and participate in ICBC’s public consultation on the proposed rules beginning in February 2026.
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