On January 1, 2027, the Restricted Insurance Agent Licence Regulation under the Financial Institutions Act (British Columbia) (the RIA Regulation) comes into effect and introduces a new restricted licensing regime for the incidental sale of certain insurance products in British Columbia (RIA Licensing). RIA Licensing allows prescribed entities to obtain a restricted insurance agency license in order to distribute specific classe(s) of insurance products incidental to their underlying business. A restricted insurance agency license is less onerous to obtain than a “full” general insurance agency license. Once the RIA Regulation comes into effect, businesses that sell one or more classes of insurance products covered under the RIA Regulation will require RIA Licensing in order to continue distributing such classes of insurance products.
The Insurance Council of British Columbia (ICBC) is responsible for creating the regulatory framework governing the RIA Licensing regime and will be responsible for the issuance and administration of RIA Licensing in British Columbia.
Types of businesses and classes of insurance captured by the RIA Regulation
The types of businesses captured by the RIA Regulation (i.e., prescribed classes of persons) and the corresponding classes of insurance that such businesses are permitted to distribute while holding RIA Licensing are summarized in the table below. Under the RIA Licensing regime, employees and contractors of the businesses holding RIA Licensing are permitted to undertake the incidental sale of insurance. Accordingly, only corporate RIA Licensing will be issued, and individuals undertaking the incidental sale of insurance on behalf of the applicable business will not hold individual RIA Licensing, unlike the existing ICBC unrestricted insurance agency licensing regime that requires both corporate agency licensure and individual licensure.
Motor vehicle dealers holding RIA Licensing will not be able to sell products falling under the class of automobile insurance in British Columbia. This means that motor vehicle dealers in British Columbia holding RIA Licensing cannot distribute motor vehicle appearance protection products (since such products are considered automobile insurance in British Columbia and would require distribution by persons holding full insurance agency/agent licensing in the province).
| Type of business (captured by the RIA Regulation) | Classe(s) of insurance such business may distribute with RIA Licensing |
| Construction equipment dealerships | • Credit protection insurance • Construction equipment warranty insurance • Guaranteed asset protection insurance |
| Credit grantors | • Credit protection insurance |
| Customs brokers | • Cargo insurance |
| Deposit-taking institutions | • Credit protection insurance |
| Extra-provincial trust corporations | • Credit protection insurance |
| Farm implement dealerships | • Credit protection insurance • Farm implement warranty insurance • Guaranteed asset protection insurance |
| Freight-forwarding companies | • Cargo insurance |
| Funeral providers | • Funeral services insurance |
| Mortgage brokerages | • Credit protection insurance |
| Motor vehicle dealers | • Credit protection insurance • Guaranteed asset protection insurance • Vehicle warranty insurance |
| Peer-to-peer vehicle service providers | • Rented vehicle insurance |
| Pleasure craft dealerships | • Credit protection insurance • Guaranteed asset protection insurance • Pleasure craft warranty insurance |
| Portable electronic vendors | • Portable electronics insurance |
| Transportation companies | • Cargo insurance • Travel insurance |
| Travel agents | • Rented vehicle insurance • Travel insurance |
| Travel wholesalers | • Rented vehicle insurance • Travel insurance |
| Trust companies | • Credit protection insurance |
| Vehicle rental agencies | • Rented vehicle insurance |
Next steps for the implementation of the RIA Licensing regime
As a general note, a person cannot distribute insurance products in British Columbia without holding the proper insurance agent or agency licensing. As indicated above, commencing on January 1, 2027, businesses captured by the RIA Regulation that undertake the incidental sale of one or more classes of insurance permitted under the RIA Regulation must hold RIA Licensing. Businesses captured by the RIA Regulation will have until March 31, 2027 to submit their respective applications for RIA Licensing in order to distribute insurance in a compliant manner in British Columbia. In addition, holders of restricted travel insurance licensing in British Columbia will have until December 31, 2027 to transition to the new RIA Licensing for the class of travel insurance. The ICBC anticipates that it will start accepting applications for RIA Licensing in November, 2026.
Businesses captured by the RIA Regulation that choose not to pursue RIA Licensing will be considered in contravention of the Financial Institutions Act (British Columbia) and may be subject to enforcement action by the ICBC.
The ICBC also announced that additional information on the RIA Licensing regime will be released in January, 2026. The ICBC will also engage in public consultations with, among others, industry stakeholders for their respective feedback on the proposed RIA Licensing regime and its associated regulatory framework.
This article forms part of a series of articles that Dentons Canada’s corporate and regulatory insurance team will publish on RIA Licensing, as further updates are released by the ICBC.
Dentons Canada’s corporate and regulatory insurance team is available to assist businesses involved in the incidental sale of insurance in British Columbia in complying with the new RIA Licensing regime (including assisting businesses with preparing and submitting the requisite applications for RIA Licensing to the ICBC). For more information on this topic, please reach out to Laurie LaPalme, Derek Levinsky, Marisa Coggin and Jesse Collins-Swartz, or any member of Dentons’ corporate and regulatory insurance group
