On November 3, 2025, the Registered Insurance Brokers of Ontario (RIBO) introduced, for public consultation, proposed changes to the supervision requirements applicable to RIBO licensees (the Proposed Changes). RIBO states that the goal of the Proposed Changes is to enhance supervision efficacy and support a stronger adherence by licensees to applicable laws and regulatory guidance.
The Proposed Changes are not final and may be subject to further change and public consultation by RIBO.
This article provides a summary of the Proposed Changes and potential implications for the insurance industry.
What are the proposed changes introduced by RIBO?
RIBO notes that the Proposed Changes consist of several proposals that aim to strengthen the role of the principal broker for RIBO licensed entities (the Principal Broker) and lead to more meaningful supervision.
For context, according to RIBO’s 2024-2025 Annual Report, the vast majority of RIBO licensees hold a Level 1 license (19,169, as compared to 1,971 Level 2 licensees and 1,605 Level 3 licensees). Under the existing RIBO By-Law No. 3 dated March 2024, Level 1 licensees must be supervised by a Principal Broker, the deputy Principal Broker or a supervising broker (all of whom must maintain a Level 3 license).
The Proposed Changes are summarized in more detail below.
- Defining supervision
RIBO intends to clarify the requirement for new licensees to act under supervision and define what is meant by the term “supervision.” This includes permitting Level 1 RIBO licensees to act under the supervision of another a RIBO Level 1 licensee who has held RIBO licensing for at least 36 months, or a Level 2 or a Level 3 RIBO licensee who has held RIBO licensing for at least 24 months.
2. Supervision standards for Principal Brokers
RIBO proposes that new principles-based supervisory standards be incorporated by Principal Brokers into their respective plans of supervision. This includes ensuring RIBO licensed entities’ plans of supervision include the following:
- assessing the suitability of employees or individuals prior to licensure or formalizing sponsorship;
- placing restrictions on RIBO licensees under supervision where they lack the skills, knowledge and/or competencies to offer and sell insurance products;
- identifying the insurance skills, knowledge and competencies a RIBO Level 1 licensee should demonstrate before being able to sell insurance;
- developing training systems for RIBO licensees to advance their technical insurance skills, knowledge and competencies;
- regularly reviewing insurance sales, renewals, policy amendments and recommendations made by RIBO licensees;
- documenting any reviews made by the supervisor in the customer’s file; and,
- developing a response plan to correct errors and omissions made by a RIBO licensee in the sale, renewal, amendment or cancellation of a policy of insurance.
3. Size-specific supervision requirements
The Proposed Changes include requiring the appointment by a RIBO entity of one or more deputy Principal Brokers or supervising brokers for every 20 RIBO licensees employed by such entity. RIBO aims to give Principal Brokers the flexibility to determine how best to organize the appointment and the role of the applicable entity’s deputy Principal Brokers and supervising brokers.
At this time, licensees that have signed the RIBO wholesale broker undertaking (i.e. who are not authorized to conduct insurance business directly with the public) would be exempt from the application of this Proposed Change.
4. Geographic supervision requirements
RIBO is also introducing requirements applicable to the supervision by Principal Brokers of RIBO licensees who work remotely (i.e. in a physical location separate and apart from the location where the Principal Broker undertakes their work on behalf of the RIBO licensed entity). Although specific remote work guidance is still forthcoming from RIBO, RIBO licensees conducting business in a location different from where the Principal Broker conducts their business on behalf of a RIBO licensed entity must be supervised in a way that is equivalent to the supervision that the Principal Broker would provide if such licensees were working together in-person.
5. Limitation on the number of unaffiliated entities Principal Brokers may supervise concurrently
The Proposed Changes include a restriction that Principal Brokers may not supervise more than three unaffiliated RIBO licensed entities at one time. RIBO (likely through its Qualifications and Registration Committee) may grant exceptions to this restriction on a case-by-case basis.
Potential implications for the insurance industry
We expect that certain proposed changes will be welcomed by the industry, including permitting RIBO Level 1 licensees to act under the supervision of other experienced licensees who may not hold a RIBO Level 3 license.
The additional requirements for size specific supervision aim to promote accountability and provide a framework for improved supervision of RIBO licensees. It is not clear from the information published by RIBO to date whether supervising brokers, under the Proposed Changes, will be subject to the same regulatory obligations and standard of care as a Principal Broker. Depending on the obligations placed by RIBO on supervising brokers under the Proposed Changes, this requirement will necessitate more vigilance from an operational and compliance standpoint to ensure that proper oversight is in place.
Brokerages’ adapting supervision policies and procedures for remote working conditions is not new, as most brokers had to implement such changes during the COVID-19 pandemic. In some brokerages, it was a seamless transition as they had adopted the necessary technology. Practically speaking, in a large brokerage, a supervisor could only be three floors up from the broker being supervised “remotely.” For example, remote oversight controls adopted by certain brokerages leverage technology to allow a supervising broker to remotely attend client calls and provide the same degree of supervision to a licensee as would be provided in person. In an evolving industry where artificial intelligence already facilitates certain customer interactions with RIBO licensees, proper supervision and controls are of the upmost importance for brokerages of all sizes.
However, the proposed limitation on the number of unaffiliated entities that can share one Principal Broker may do more harm than good. It may result in reduced foreign investment and competition in the Ontario property and casualty insurance market. New entrants do rely on Principal Brokers on a short-term, contract basis (when first establishing their respective businesses in Canada), as such new entrants (who generally hold insurance intermediary licensing outside of Canada and have significant insurance experience) are often not entitled to licensing equivalency in Ontario and are required to sit or write examinations, take additional courses, and go through the entire RIBO licensing and seasoning process.
Ontario is a major jurisdiction for most market participants. Accordingly, the proposed limitation on Principal Brokers may have a detrimental impact on the national property and casualty insurance market if it is not coupled with enhanced recognition of foreign licensing held by new entrants. Alternatively, Principal Brokers should be permitted to represent more than three RIBO licensed entities if such Principal Broker can demonstrate sufficient oversight and controls are in place for a particular entity.
Industry feedback on the Proposed Changes may be submitted to RIBOsurvey@ribo.com until January 31, 2026.
Dentons’ corporate and regulatory insurance team is available to assist current and prospective RIBO licensees with navigating the Proposed Changes and its potential impacts on their respective businesses.
For more information on this topic, please reach out to Laurie LaPalme, Marisa Coggin or Jesse Collins-Swartz, or any member of Dentons’ corporate and regulatory insurance group.
