On June 30, 2025, the Alberta Superintendent of Insurance (the Alberta Superintendent) issued Bulletin 03-2025 – Automobile insurance renewal protection following broker contract termination (the Bulletin). The purpose of the Bulletin is for the Alberta Superintendent to provide its interpretation of certain provisions of the Insurance Act (Alberta) (the Alberta Act) as they apply to renewals of private passenger (i.e., non-commercial) automobile insurance policies (PPV Policies and each a PPV Policy) in circumstances where a commercial relationship between a particular insurer and an insurance broker is terminated.
In particular, the Alberta Superintendent observed instances where upon the termination of a commercial arrangement between an insurer and an insurance broker (i.e., where the broker no longer has authority to place business with a particular insurer), certain insurers have refused to renew certain PPV Policies when an insured attempts to renew their PPV Policy with the same insurer but using a different licensed broker (as such insured’s former broker is no longer authorized to transact business with the insurer who currently underwrites the insured’s PPV Policy). The Bulletin ultimately aims to ensure the fair treatment of customers in Alberta when renewing PPV Policies.
Alberta Superintendent’s expectations for insurers regarding PPV Policy renewals
When an insured attempts to renew their PPV Policy by keeping the same insurer but while using a different licensed broker in Alberta, the insurer must treat the insured as a renewing customer (inclusive of applying all applicable premium protections and offering coverage options consistent with those of a renewing customer). The Alberta Superintendent notes that at a minimum the premium and coverage options offered to the insured for the renewal of their PPV Policy must be the same as those that would have otherwise been offered to the insured had they proceeded with the renewal of their PPV Policy using their prior insurance broker.
The Alberta Superintendent notes that insurers and brokers must override any internal system constraints that may restrict their ability to implement the contents of the Bulletin. However, insurers and brokers are permitted to change the applicable policy number for an insured’s PPV Policy where the insurer’s or broker’s internal systems do not allow a policy number to be maintained when a different broker is used for a renewal.
Actions insurers are prohibited from undertaking
The Bulletin lists the following actions that insurers are not permitted to undertake when renewing a PPV Policy where there has been a change in the broker (but the insurer remains the same):
- Refusing to renew a PPV Policy since the insurer no longer conducts business with the broker who originally placed the policy.
- The insurer charges a premium greater than what the renewal premium would have been had the insured’s broker not changed (inclusive of the Alberta “Good Driver” rate cap, if applicable).
- The coverage offered to the insured is more restrictive than the coverage that would have been offered to the insured had their broker not changed.
Penalties applicable to insurers for non-compliance
Insurers that do not comply with the applicable provisions in the Alberta Act, which forms the basis of the contents of the Bulletin, may be subject to certain administrative penalties and fines described in the Alberta Act. Administrative penalties are set at a maximum of CA$25,000 for each contravention of the applicable provision of the Alberta Act, and where an insurer is found guilty of an offense under the Alberta Act, the insurer may be subject to a fine of not more than CA$200,000 for each day that the offense occurred or continued.
Next steps for insurers and brokers writing PPV Policies in Alberta
Insurers and brokers writing PPV Policies in Alberta should review their underwriting, rating and customer service policies and procedures to ensure such documents include proper written controls to avoid contravening the provisions of the Alberta Act discussed in the Bulletin.
Dentons Canada’s Corporate and Regulatory Insurance groups would be pleased to discuss the contents of the Bulletin further and to assist insurers and brokers with ensuring the Bulletin’s effective implementation into their respective operations and compliance regimes.
