The purpose of this consultation is to collect feedback from the public, licensees, industry associations, and other interested parties to strengthen RIBO’s supervisory model.
RIBO is currently exploring proposals to improve its supervision model. If these proposals are approved, they may lead to changes to RIBO By-Laws, education standards and other adjustments needed to implement the new policies.
The consultation was open from November 3, 2025, to March 31, 2026. See RIBO’s response that summarizes the feedback received and outlines our proposed direction and next steps.
The Registered Insurance Brokers of Ontario (RIBO) was established in 1981 as a self-regulatory body for insurance brokers in Ontario.
Insurance brokers serve as intermediaries between customers and insurance companies, acting in the customers’ best interests.
All individuals or firms who meet the legislative definition of an insurance broker must be licensed by RIBO. (See note below.)
RIBO is mandated to protect the Ontario public interest in their dealings with insurance brokers. It fulfills this mandate by establishing minimum licensing qualifications, defining standards for professional competence and ethics, and outlining financial and insurance-related requirements for RIBO-registered firms.
Under the Registered Insurance Brokers Act (RIB Act), RIBO has the authority to build upon existing requirements related to supervision. Section 6.1 of RIBO By-Law 3 also authorizes RIBO’s Council to amend the requirements imposed on Principal Brokers (PBs), including requirements for a supervision plan.
Learn more by visiting our About RIBO webpage.
Note:
“Insurance broker” means any person who for any compensation, commission or other thing of value, with respect to persons or property in Ontario, deals directly with the public and:
(a) acts or aids in any manner in soliciting, negotiating or procuring the making of any contract of insurance or reinsurance whether or not the person has agreements with insurers allowing the person to bind coverage and countersign insurance documents on behalf of insurers,
(b) provides risk management services including claims assistance where required,
(c) provides consulting or advisory services with respect to insurance or reinsurance, or
(d) holds himself, herself or itself out as an insurance consultant or examines, appraises, reviews or evaluates any insurance policy, plan or program or makes recommendations or gives advice with regard to any of the above; (“courtier d’assurances”)
In the 2022-2025 Strategic Plan, RIBO committed to reviewing its licensing framework. As part of this review, RIBO has identified a need to bolster its existing supervisory framework to ensure it is relevant to today’s industry and prepares licensees to provide advice and respond to the needs of customers.
To ensure that licensees can meet these demands, RIBO has committed to completing this review as part of its upcoming 2025-2028 Strategic Plan.
Insurance brokers are facing an increasingly complex industry and the demands on them are only growing from their customers, insurer-partners, and regulators. The distribution of relatively simple products like personal auto insurance has also grown more complex over time. PBs need to meet these challenges all while effectively managing their brokerages and remaining in compliance with insurance laws and other requirements impacting their business.
This review will assist RIBO in better supporting consumer protection by developing competent and resourceful licensees who are both able to meet their customers’ needs and understand the regulatory system in which they operate.
A fundamental principle found in nearly all regulated professions is the concept of supervision. This principle places ultimate accountability on a single individual within the firm to ensure that the firm, as well as unlicensed and licensed employees of the firm comply with applicable legislation.
These individuals are expected to be compliance experts. This includes, but is not limited to, providing leadership and guidance to the licensees they supervise, and establishing policies and procedures that lead to licensees treating the public fairly, competently, and ethically.
This approach to supervision is largely set out in the Principal Broker Handbook and has been reinforced more generally through RIBO’s approach to regulating the sector.
The firms RIBO licenses are larger and more complex and sophisticated in their operations, making direct supervision by a single PB impractical. At the same time, those same reasons make direct supervision even more necessary.
RIBO envisions a new approach to supervision that enhances the PB’s overarching supervision responsibilities by reinforcing individuals’ and supervisors’ joint responsibility for ensuring fairness for insurance customers.
Firms are unable to hold a licence unless they are under the direction and supervision of a PB. This is a requirement within the RIB Act. Licensees must also act under the supervision of a PB.
RIBO believes that licensees should all have the opportunity to seek guidance and receive direct supervision from a qualified individual from the firm at any time. In addition, new licensees should be provided with enhanced levels of supervision to support their career development and professional growth.
Section 6.1 of RIBO By-Law 3 imposes several responsibilities on PBs that form the foundations of RIBO’s supervisory model. PBs are explicitly mandated to provide direction, supervision, and information respecting insurance to their licensees and employees. In discharging these responsibilities, the PB is required to exercise reasonable diligence.
A key aspect of the supervisory model and how RIBO enforces the above requirement is mandating that the PB have a written Plan of Supervision that sets out the policies and procedures to ensure compliance with RIBO’s legislation.
The Plan of Supervision does not need to be formally approved by RIBO but must include certain elements which are outlined in the Principal Broker Handbook and the Code of Conduct Handbook. For example, the Plan of Supervision must include record keeping policies dealing with file ownership and acceptable file maintenance.
To support PBs in drafting their Plan of Supervision, RIBO has published guidance documents and articles in the RIBO Review monthly bulletin that prescribe expected outcomes PBs must achieve, as well as how they might achieve those outcomes by including considerations as part of the PB’s Plan of Supervision for the firm. This principles-based approach for supervision allows PBs to adopt supervision plans that are unique to the size and sophistication of the firm.
RIBO’s legislation holds PBs accountable for ensuring compliance of the firm and individual licensees with the RIB Act, its regulations, By-Laws, and other applicable legislation. When the legislation was drafted, it was assumed that PBs would either be owner-operators or full-time employees of their firm and be personally on location. This meant that firms and employees would receive direct supervision from their PBs in a monitored environment.
New technologies, regulatory developments and business models have disrupted this model. While technologies and business models enabled new modes of supervision, it has introduced significant challenges. Firms now employ more licensees than ever before, have office locations distributed across the province and operate in a far more complex regulatory environment than when RIBO was first established.
Furthermore, remote work is becoming a more common practice in the industry as governments pass labour mobility legislation. PBs must now, more than ever, prioritize delivering meaningful and consistent supervision to licensees across the country. Together, such factors place more demand on the skills and knowledge of PBs to manage these risks. It is becoming difficult for a single PB to manage these risks or provide direct supervision to the employees of the firm.
A business model has also emerged over time where non-owner qualified PBs are offering supervision services on a contractual basis to several unrelated RIBO entities. Such multi-firm PBs fill a much-needed gap in supervision for a firm on a temporary basis or for the purpose of fulfilling registration requirements during the start of phases of the business. In other cases, however, this model of supervision is being employed long term.
Insurance intermediary regulators have seen these trends and responded by taking various approaches to decentralize supervision beyond a single individual within the firm. For example, both the Autorité des marchés financiers (AMF) and the Insurance Council of British Columbia have developed comprehensive guidelines that describe their expectations of PBs and licensees who act in a supervisory capacity.
In these models, the PB implements policies and procedures regarding supervision and delegates a level of compliance monitoring to other staff of the firm. Licensees who are delegated responsibility for supervision of other licensees (i.e., supervisees) must provide guidance and education to the supervisees and training reports to the PB and/or the regulatory on the supervisees’ performance. RIBO By-Law 3 sets out the ability for PBs to appoint Deputy PBs and Supervising Brokers. These roles appear to be underutilized within existing plans of supervision, potentially due to the licensing requirements to obtain these statuses.
RIBO has identified several proposals that could strengthen the role of the PB and lead to more meaningful supervision. The proposals are not yet finalized. They may be subject to further consultation and change.
RIBO is seeking your feedback on the following proposals:
We welcome insights from all RIBO licensees and encourage you to share any additional comments or feedback you may have regarding the proposals by March 31, 2026.
RIBO has prepared a set of questions to help guide your feedback.
Please email any comments, questions or feedback to ribosurvey@ribo.com.
1. Should Level 1 licensees be required to act under the supervision of another experienced licensee for a defined period? Why or why not?
2. How many years should that person be licensed before they can qualify to supervise Level 1 licensees? Does their licence level matter?
3. What resources or guidance should RIBO develop to ensure supervisors can effectively oversee newly licensed brokers?
4. Are you supportive of introducing principles-based supervisory standards that Principal Brokers must achieve? Why or why not?
5. What challenges do you foresee in incorporating these standards into your firm’s Plan of Supervision (e.g., negatively impacting customers, creating unintended consequences, incompatibility with existing supervision model)? If so, what standards should be amended, deleted, or added?
6. Are you supportive of introducing a supervision ratio that requires the appointment of one or more Deputy Principal Broker(s) or Supervising Broker(s) for every 20 licensees employed by a firm? Why or why not?
7. Are there alternative models to achieve a similar outcome of having a readily available supervisor?
8. What mechanisms, policies, and/or procedures need to be in place to ensure that remote supervision is equivalent to in-person supervision?
9. How do you provide or receive remote supervision? Do you find it as effective as or equivalent to in-person supervision?
10. Should there be a limit on the number of unrelated firms (i.e., separate legal entities with no common ownership) that can be supervised by a single Principal Broker? Why or why not?
11. If a limit is imposed, what factors should the Qualification & Registration Committee consider when evaluating exemption applications?
12. If your organization employs automated quoting tools or Artificial Intelligence (AI) systems, what mechanisms are in place to ensure effective oversight, accountability, and compliance?
13. How can RIBO be more effective at communicating our supervision expectations?