On October 28, 2025, the Financial Services Regulatory Authority of Ontario (FSRA) released the 2025 Auto supervision interim report (the Report). The Report summarizes FSRA’s findings from reviews conducted by FSRA between January, 2024 and March, 2025 of five insurers (the Reviews) writing automobile insurance business in Ontario (collectively, the Auto Insurers). The Report and associated Reviews are part of FSRA’s Auto Insurance Supervision Plan (the Plan) released in December 2023. As set out in the Plan, FSRA has prioritized the examination of automobile insurer’s activities in the areas of distribution, underwriting and policy administration. The Reviews are also in-line with FSRA monitoring the compliance of insurers conducting automobile insurance business with FSRA’s Take-All-Comers Rule (the TAC Rule).This article summarizes certain key findings from the Report and corresponding action items for insurers writing automobile insurance business in Ontario.
Auto insurer activities that posed the potential for consumer harm
The Reviews include FSRA’s findings in respect of activities that FSRA considered posed the greatest potential for consumer harm, as summarized below. FSRA was particularly interested in assessing how the Auto Insurers upheld their market conduct obligations across key stages of the automobile insurance product lifecycle.
- Sales and distribution
As part of the Reviews, FSRA assessed whether the Auto Insurers had appropriate controls to ensure that only approved underwriting rules were used to refuse the issuance of quotes, decline coverage, or cancel policies. In addition, FSRA determined whether effective processes were in place to ensure customers were provided with key information (e.g. premium amounts, policy benefits, contract duration, limitations, conflicts, exclusions and customer rights and obligations) as part of the suite of information disclosed by the Auto Insurers to their customers at the time of quoting.
2. Underwriting
FSRA focused its underwriting-related review on the Auto Insurers’ automated underwriting systems. FSRA was particularly interested in reviewing instances where applications for automobile insurance met the Auto Insurers’ filed underwriting guidelines but were still referred by the automated underwriting system for manual review, as this process could be indicative of non-compliance with the TAC Rule and/or the Insurance Act (Ontario) and its regulations.
3. Policy servicing
The Reviews consider various aspects of how the Auto Insurers serviced policies; including (i) policy changes (in particular, insurer-initiated cancellations and non-renewals); (ii) claims (i.e. whether the Auto Insurers’ claims processes were fair and transparent); (iii) whether consumer complaints are handled in a timely and fair manner; and (iv) the Auto Insurers’ protocols regarding the collection, use and storage of personal information.
Identified areas of improvement
The Report identifies “Monitoring Controls” and “Documentation” as the two broad areas for improvement to be addressed by the Auto Insurers.
- Monitoring Controls
FSRA found that the Auto Insurers demonstrated limited visibility to the quality of information exchanged between brokers and clients during the automobile insurance quoting and binding process. This includes ensuring the completeness, accuracy and clarity of automobile insurance product details shared by the broker with the end customer. The Report reminds insurers that they remain responsible for ensuring that their distribution partners (including brokers) uphold service standards and support fair consumer outcomes.
FSRA also observed a lack of information, analysis and exception reporting to support manual underwriting interventions arising during the Auto Insurers’ automated underwriting processes. The Report notes that although manual interventions are not necessarily indicative of non-compliance, such manual interventions can lead to delays for consumers in the underwriting process. A delay could be evidence of a violation of the Unfair or Deceptive Acts and Practices Rule (UDAP Rule) and/or non-compliance with the TAC Rule.
FSRA also pointed out that the Auto Insurers did not consistently collect or analyze data on insurer-initiated cancellations and non-renewals of automobile insurance policies. The Report emphasizes that such information is essential for identifying trends, detecting anomalies and evaluating potential consumer impact.
2. Documentation
The Report also identifies concerns regarding the Auto Insurers’ maintenance of proper written records and documentation as part of their underwriting and servicing of policies. In particular, FSRA found documentation to support changes in underwriting rules was incomplete or lacking (specifically with respect to audit trails, approvals and workflow continuity). In addition, FSRA observed that the Auto Insurers referring claims to Preferred Provider Networks often did not have proper documentation showing that required disclosures were made and that the necessary written consents were obtained. Lastly, in certain circumstances, the Auto Insurers did not issue final position letters in all instances where consumer complaints were referred to the Ombudsperson.
Action items for insurers conducting automobile business in Ontario
FSRA concludes the Report by stating that further action is needed to ensure the fair treatment of consumers by insurers conducting automobile insurance business in Ontario. FSRA highlighted the following next steps:
- FSRA expects insurers to review the areas for improvement detailed in the Report and update their business practices (where applicable) to ensure compliance with applicable regulatory requirements and expectations. Specifically, insurers should review their processes, controls and documentation practices.
- FSRA extended its Reviews under the Auto Insurance Supervision Plan until March 31, 2026 and advised that additional reviews of insurers will be conducted and that FSRA would take associated “actions,” as needed.
- FSRA intends to release a final version of the Report following the conclusion of the additional examinations noted above.
Having regard to the findings in the Report, we recommend that insurers writing automobile insurance in Ontario consider the following practices as part of their compliance programs:
- Establish controls and systems within the underwriting environment that require proper documentation and disclosure before moving to binding risks or closing underwriting files.
- Review algorithms and underwriting rules to ensure compliance with the UDAP Rule and the TAC Rule, in particular.
- Update forms, applications and webpages to ensure proper disclosures are provided to customers.
- Conduct regular and ongoing training of brokers and agents.
- Conduct and document the results of proper audits and oversight of channel partners, as well as any remediation actions required to address compliance issues.
- Perform regular desk audits to ensure compliance.
Dentons Canada’s corporate and regulatory insurance team is available to assist insurers with their automobile insurance regulatory compliance, including reviewing insurers’ existing compliance policies and procedures against the findings and recommendations in the Report.
For more information on this topic, please reach out to authors Laurie LaPalme, Marisa Coggin and Jesse Collins-Swartz.
