As discussed in our January 6, 2026 post, British Columbia has introduced the long‑awaited Restricted Insurance Agent Licence Regulation, which will take effect on January 1, 2027, creating a new licensing framework in the province for businesses that sell insurance incidentally to their primary goods or services. The regime replaces prior exemptions and aligns British Columbia with similar regimes in Alberta, Saskatchewan, Manitoba, and New Brunswick by requiring certain non‑insurance businesses to obtain a Restricted Insurance Agency (“RIA”) licence to continue offering specified add‑on insurance products.
On January 7, 2026, the Insurance Council of British Columbia (“Insurance Council”) issued further details on proposed requirements (“Proposed Requirements”) for applicants for RIA licences. As discussed below, the Proposed Requirements address the RIA licence qualification requirements, ongoing licence requirements, disclosure requirements and the qualification standards for designated representatives and sales representatives. Details of the initiative are expected to be finalized in the coming months, with a target date of November 2026 for the commencement of the application process.
RIA Licence Requirements
Qualifying for a licence
In order to qualify for an RIA licence, an agency must:
- Provide contact information, ownership and corporate registration information and other business information relevant to suitability (e.g. past regulatory discipline, criminal convictions or bankruptcies);
- Have E&O insurance;
- Have one or more contracts with an insurer that is authorized to do business in British Columbia; and
- Appoint a Designated Representative responsible for oversight of insurance activities and regulatory compliance.
Maintaining a licence
To maintain its licence, an RIA must renew it annually and:
- Ensure that it always has a Designated Representative (see below) and notify the Insurance Council should that position become vacant;
- Ensure that their sales representatives complete an accredited course (see below);
- Comply with disclosure requirements for insurance transactions (see below);
- Maintain its E&O coverage; and
- Continue to hold one or more contracts with an insurer that is authorized to conduct business in British Columbia.
The Insurance Council anticipates that sales representatives for RIA licensees may in the future be required to complete some form of continuing education; however, this requirement will not be introduced at the time of launch..
Designated Representative
The RIA must appoint a Designated Representative to serve as a contact person and oversee the RIA’s insurance activities, including its regulatory compliance.
The Designated Representative must be an officer, director or partner of the RIA, or a sole proprietor, and must have completed the Insurance Council’s course for Designated Representatives.
Disclosure Requirements
Those selling insurance on behalf of an RIA will be required to disclose specific information in writing to prospective buyers, including:
- That insurance is optional and may be obtainable elsewhere;
- Whether the buyer can cancel the insurance contract;
- The amount of the sales commission, if it exceeds 30% of the price of the insurance product;
- That the buyer is contracting with the insurer, not the agency; and
- If applicable, whether the insurance amount is less than the value of the loan or the duration of the coverage is shorter than the duration of the loan.
The written documentation must also include the insurer’s contact information and state that the buyer will receive a copy of coverage information.
Education Standards and Performance Requirements
All RIA sales representatives would be required, at a minimum, to complete a course on the RIA’s insurance products. Such a course may be offered by any provider but must be accredited by the Insurance Council. While specific accreditation standards have yet to be released, the Insurance Council will generally evaluate proposed courses with a view to ensuring alignment with the following Performance Requirements:
- Knowledge of insurance (concepts, terminology, products, services);
- Technical abilities (sales, processing and servicing, including related legal and regulatory requirements); and
- Business skills (professional conduct/ethics, E&O, information management/record keeping).
The Performance Requirements are intended to establish a “baseline level of competence” for sales representatives of an RIA.
Applying for a Licence
The Insurance Council expects to begin taking licence applications in November 2026, with application information to be published over the coming months. The fee model has not yet been determined.
Next Steps
While the Proposed Requirements are not finalized, organizations that will require licensing can begin their compliance process at any time, e.g. by identifying a Designated Representative, taking initial steps toward developing courses for their sales representatives and ensuring that E&O insurance and the required contracts with authorized insurers are in place.
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