RIBO’s Supervision Consultation Responses

1. Supervision Outcomes

RIBO will establish supervision outcomes, refine the proposed outcomes based on consultation feedback, and develop supporting implementation guidance.

2. Supervision Period

RIBO will implement a competency-based supervision period for new-to-industry licensees. It will also introduce supervisor qualifications, appropriate exemptions, and supporting implementation tools.

3. Supervision Ratios

RIBO will not establish a fixed supervision ratio. Instead, it will implement a supervision outcome focused on ensuring timely and effective supervision.

4. Multi-Firm Principal Brokers

RIBO will not establish a cap on the number of firms a Principal Broker may oversee at this time. Instead, it will implement a supervision outcome requiring effective oversight and will continue monitoring compliance regardless of the number of firms supervised.

5. Remote Supervision

RIBO will maintain a principles-based approach to remote supervision while providing clearer expectations through guidance, evidence standards, practical tools, and updates to the Principal Broker Handbook.

6. AI and Automated Quoting

RIBO will continue to rely on its existing responsible AI guidance, clarify expectations regarding human oversight and governance where appropriate, and monitor developments in the use of AI and automated quoting tools.

7. Communication of Expectations

RIBO will strengthen its communication of supervisory expectations through enhanced guidance, training, disciplinary decisions, industry engagement, and practical implementation resources.

Summary of Consultation Responses

• Respondents’ views were broadly supportive of introducing principles-based supervision outcomes for Principal Brokers, with a clear preference for flexible, risk-based, and outcome-focused expectations rather than prescriptive rules.
• Broad agreement that supervision must be meaningful, documented, and demonstrably effective, regardless of firm size, structure, geography, business model, or supervisory approach.
• Respondents emphasized that supervision outcomes should be scalable and proportionate, recognizing the differences between small community brokerages, start-ups, MGAs, national firms, and large or complex organizations.
• A recurring concern was that fixed ratios, quotas, mandatory supervisory structures, or rigid Level 3 licensing requirements could undermine a principles-based framework and encourage checklist compliance rather than effective oversight.
• Strong support was expressed for allowing Principal Brokers to delegate supervisory and administrative functions within controlled governance frameworks, provided accountability, reporting lines, oversight, and escalation pathways remain clear.
• Respondents emphasized that modern supervision may be supported by compliance teams, HR, licensing, finance, internal audit, managers, team leads, technology, monitoring tools, training programs, and centralized controls.
• Common concerns were raised about role clarity and accountability, with respondents stressing that ultimate responsibility should remain with the Principal Broker while avoiding confusion or duplication with existing management and compliance structures.
• Several respondents distinguished RIBO’s role in assessing licensing suitability and setting examination standards from the brokerage’s role in monitoring ongoing employment suitability, sponsorship, conduct, product capability, and competency.
• Respondents supported consistent documentation and reporting expectations, but cautioned that confidential supervisory reviews or performance-related comments should not necessarily be recorded in customer files.
• There was broad support for RIBO providing practical implementation tools, including guidance, templates, checklists, examples of acceptable evidence, case studies, targeted training, and clearer expectations for audits and compliance reviews.

Proposed Direction

RIBO is proposing to introduce supervision outcomes that Principal Brokers would be required to incorporate into their Plans of Supervision. Establishing supervision outcomes provides an opportunity to align firm supervision with RIBO’s mandate, where licensees and the public are well informed and protected, and where transactions are conducted fairly.

Consultation Feedback

The consultation feedback was broadly supportive of introducing supervision outcomes. Respondents generally agreed that clear outcomes can help reduce ambiguity in how supervision expectations are interpreted and applied across firms, while supporting more consistent regulatory oversight.

Refinements Based on Feedback

In response to the feedback received, RIBO will continue to refine the proposed outcomes before finalizing them. In particular, RIBO will consider amending or removing outcomes that may be inappropriate or impractical. For example, RIBO recognizes concerns about requiring supervisory reviews to be documented directly in client files and it will be removed. RIBO will also consider reviewing suitability-related outcomes to also focus on a firm’s responsibility to monitor ongoing suitability, conduct, and competency.

Scalability and Proportionality

RIBO recognizes that supervision requirements must remain flexible and proportionate. The outcomes are not intended to prescribe a single supervision structure or require firms to adopt identical processes. Brokerages vary significantly in size, complexity, geography, business lines, staffing, and governance models. The supervision outcomes should therefore be capable of being applied by small, mid-sized, large, specialized, and multi-jurisdictional firms in a manner that reflects their operational realities and risk profile.

Implementation Tools and Industry Engagement

RIBO will also remain cognizant that Principal Brokers should be able to use appropriate delegation, governance structures, and supervisory systems to meet the outcomes. To support implementation, RIBO will consider what tools and resources should be developed for Principal Brokers and firms. These may include guidance materials, examples of acceptable evidence, checklists, reporting templates, FAQs, or case studies. RIBO may also consult or work with industry associations and other respondents, as needed, to ensure the guidance is practical and supports consistent understanding across the sector.

Summary of Consultation Responses

• Broad support for introducing a supervision period for newly licensed or new‑to‑industry licensees.
• Respondents consistently linked early‑career supervision to enhanced consumer protection, reduced error risk, and improved regulatory outcomes.
• Strong recognition that new‑to‑industry licensees must demonstrate competence and gain practical experience before operating independently.
• Clear support for exemptions from the supervision period to recognize prior insurance industry experience, out‑of‑province licensing, or equivalent qualifications.
• Consensus that supervision should be competency‑based, with the duration tied to demonstrated readiness rather than a fixed time requirement.
• Acknowledgement of complexity in determining supervisor eligibility; while licence level may be a useful indicator, respondents emphasized the importance of experience, subject‑matter expertise/alignment, and leadership capability.
• One respondent recommended the development of a supervisor‑specific course if Level 1 licensees are permitted to supervise.
• Need for clearer delineation between the role of a supervisor and the Principal Broker, to avoid blurred accountability.
• Expectation that RIBO will develop implementation supports, including competency checklists, supervision plans, training, forms, and performance metrics.

Proposed Direction

RIBO intends to introduce a competency-based supervision period for new‑to‑industry licensees, defined as individuals who have not previously held an insurance licence and do not have prior insurance training or comparable industry experience.

Duration and Competency Milestones

RIBO is proposing a supervision period would continue until the licensee demonstrates the required competencies. Further work will be undertaken to define what and how competency milestones are established and assessed. The intent is to emphasize demonstrated readiness rather than reliance on a fixed time requirement alone.

Supervisor Qualifications

RIBO will further examine what qualifies an individual to act as a supervisor by undertaking an occupational analysis to identify the appropriate skill sets, experience, and any additional educational or training requirements that may be needed for supervisors.

Implementation Supports

To support implementation, RIBO will develop guidance and tools that firms can use to design or enhance their supervision systems, such as competency frameworks, supervision plans, templates, and supporting resources. The intent is to complement existing supervisory structures, not disrupt them.

Exemptions and Flexibility

RIBO also recognizes the need for exemptions or flexibility from the supervision period where appropriate, including but not limited:

• Out‑of‑province licensing or equivalent experience, or
• Relevant insurance industry experience obtained through equivalency pathways or related roles.

Summary of Consultation Responses

• Respondents were predominantly not supportive of introducing a fixed supervision ratio, favouring a principles-based, flexible approach instead.
• Broad agreement that supervision quality is not driven by headcount, but by governance, controls, training, and effective oversight.
• Respondents emphasized that supervision must be risk-based, scalable, and proportionate, reflecting differences in firm size, complexity, and business model.
• A recurring concern was that fixed ratios are arbitrary and risk-blind, and may encourage “check-the-box” compliance rather than meaningful supervision.
• Significant operational and cost challenges were identified, including limited Level 3 capacity, administrative burden, and structural constraints.
• Strong support for recognizing layered and modern supervision models, including team leads, compliance functions, and technology-enabled monitoring.
• Broad support for allowing delegation within formal governance frameworks, while maintaining clear accountability with the Principal Broker.
• Concerns were raised about cross-jurisdictional duplication and unclear accountability, particularly for nationally operating firms.
• A minority of respondents supported ratios as a baseline safeguard, but generally favoured flexibility or exemptions where robust systems exist.
• Respondents consistently supported a shift toward evidence-based supervision, where firms demonstrate effectiveness through documented plans, controls, and outcomes rather than prescribed structures.

Decision

RIBO will not be proceeding with the introduction of a fixed supervision ratio. Based on consultation feedback, there is insufficient evidence that a prescribed ratio would result in more meaningful or effective supervision than could be achieved through less disruptive, outcomes-based approaches.

Operational Considerations

RIBO recognizes the significant operational challenges associated with implementing a fixed ratio, as identified by respondents. These include the limited availability of Level 3 licensees, the cost and time required to recruit or upskill supervisory staff, and the potential disruption to established supervision frameworks that are currently functioning effectively. Respondents also noted structural constraints, including governance and officer requirements, as well as challenges for firms operating across multiple jurisdictions.

Rationale

RIBO acknowledges that imposing a uniform ratio risks encouraging formal compliance rather than enhancing the quality of supervision, and may not reflect the diversity of brokerage business models, risk profiles, and organizational structures.

Alternative Approach

Instead, RIBO will focus on refining the proposed supervision outcomes to better emphasize the importance of access to effective and timely supervision, including the expectation that licensees have a readily available supervisor or equivalent oversight.

Implementation Principle

This approach will provide firms with the flexibility to design and implement supervision structures that are tailored to their size, complexity, and operating model, while ensuring that supervision remains effective, accountable, and aligned with consumer protection objectives.

Summary of Consultation Responses

• Respondents’ views were mixed on imposing a limit on the number of unrelated firms a single Principal Broker may supervise, with no clear consensus on a fixed numerical cap.
• Broad agreement that supervision must be meaningful, documented, and demonstrably effective, regardless of how many firms are supervised.
• Concerns were raised that limits could negatively impact market entry, competition, and access to experienced compliance expertise for smaller or start‑up firms.
• Some respondents who supported a cap emphasized consumer protection concerns, including risks of diluted or nominal oversight, reduced day‑to‑day involvement, and increased likelihood of compliance failures.
• A recurring concern was the potential commercialization of the Principal Broker role (e.g., “rent‑a‑DI” models), where supervision may be administrative or nominal rather than embedded and effective.
• Some respondents opposed a hard cap, advocating instead for a risk‑based, principles‑focused approach that considers firm size, complexity, governance infrastructure, and supervisory capacity, including time, experience, competing responsibilities, and ability to maintain active oversight.
• Strong emphasis on the importance of governance infrastructure and delegated supervision, including documented Plans of Supervision, deputy or supervising broker roles, compliance resources, monitoring processes, and clear escalation pathways.
• Common view that temporary or transitional multi‑firm supervision (e.g., start‑ups, acquisitions, illness, or sudden departures) is appropriate, but should be time‑limited and clearly justified.
• Broad support for enhanced regulatory oversight tools, including supervision frameworks, audit rights, attestations, and the ability to review or revoke arrangements where supervision quality deteriorates.
• If a cap is imposed, RIBO should clearly define the criteria for any exemption or approval process, with respondents identifying key factors such as firm risk profile, business complexity, governance infrastructure, Principal Broker capacity, compliance history, and the robustness of a documented Plan of Supervision.

Current Position

RIBO acknowledges the importance of carefully addressing multi-firm Principal Broker supervision. RIBO will not implement a cap at this time. While RIBO recognizes that there is potential for consumer harm where oversight becomes diluted or nominal in multi-firm arrangements, however, that moving too quickly to impose a cap could create unintended consequences.

Evidence provided during the consultation suggested a cap may limit market entry, reduce competition, and restrict access to experienced compliance expertise, especially for smaller or start-up firms, thereby exposing the public to different but equally important risks.

Outcomes

RIBO will introduce outcomes that emphasize the quality and effectiveness of oversight rather than the number of firms supervised. Under this approach, Principal Brokers will be expected to demonstrate that they can effectively discharge their supervisory responsibilities, maintain meaningful oversight of all licensees, and ensure that supervision remains active, documented, and proportionate to the risks presented by the firms they oversee. Ongoing monitoring of these outcomes may in future reveal a need for further or more prescriptive requirements.

Further Assessment

The development of supervision outcomes and related performance measures will help address the current evidence gap regarding multi-firm Principal Broker arrangements. Monitoring these outcomes will provide RIBO with a stronger understanding of whether existing practices are producing the desired supervisory results or whether additional regulatory measures may be required in the future.

Summary of Consultation Responses

• Respondents were broadly supportive of remote supervision being considered equivalent to in-person supervision, provided it is outcomes-based and effectively implemented.
• Strong consensus that supervision should be activity-based rather than location-based, with effectiveness determined by oversight, access, and accountability rather than physical presence.
• Broad agreement that technology-enabled supervision (e.g., BMS systems, call recording, digital audits, dashboards) can support equal or enhanced supervision outcomes.
• Respondents emphasized that effective supervision is driven by governance, systems, and controls, not proximity or in-person monitoring.
• Strong support for distributed supervision models, including the use of managers, team leads, compliance functions, and centralized quality assurance teams.
• Respondents consistently supported that the Principal Broker’s role is to ensure a fit-for-purpose supervision framework, rather than personally overseeing all activity.
• Common supervisory mechanisms identified include structured check-ins, file audits, performance management systems, escalation protocols, and documented review processes.
• Broad support for risk-based and proportionate supervision, including enhanced oversight for new or higher-risk licensees and flexibility for experienced brokers.
• A recurring theme was the importance of documentation and auditability, with calls for clear evidence of supervisory activity (e.g., audit trails, logs, review records).
• Several respondents requested regulatory clarity on evidence expectations, including audit checklists, documentation standards, and examples of acceptable practices.
• Some respondents highlighted gaps in practice, noting that remote supervision can be ineffective where supervision is infrequent, informal, or lacks structure and accountability.
• Concerns were raised that remote models may reduce informal learning and in-person visibility, particularly for less experienced licensees.
• A minority of responses emphasized that remote supervision is not inherently equivalent in practice, and requires intentional design, monitoring, and enforcement to achieve comparable outcomes.

Consultation Feedback

RIBO appreciates the thoughtful feedback provided by respondents, which offered valuable insight into how remote supervision operates in practice across different brokerage models.

Guidance and Implementation Support

To support effective implementation, RIBO will consider enhancing existing guidance, including updates to the Principal Broker Handbook, to better reflect modern supervision practices. This may include non-mandatory guidance with examples of effective supervisory practices, remote supervision audit checklists, clarification of minimum expectations for evidence of supervision, templates, tools, and case studies. RIBO will continue to maintain a principles-based approach that allows flexibility while reinforcing clear accountability.

Summary of Consultation Responses

• Respondents strongly emphasized that accountability must remain with licensed individuals, with broad agreement that AI outputs cannot replace professional judgment and must be subject to human review.
• There was strong consensus on the importance of ‘human-in-the-loop’ supervision, with AI-generated outputs treated as inputs to, rather than substitutes for, broker decision-making.
• Respondents consistently identified the need for robust governance frameworks, including formal AI policies, defined roles and responsibilities, training requirements, and escalation protocols.
• Respondents emphasized the importance of auditability and documentation, including audit trails, documentation of logic and data sources, and clear distinction between automated outputs and broker advice.

Consultation Feedback

RIBO appreciates respondents’ feedback regarding how Artificial Intelligence (AI) and automated quoting tools are being used across brokerages, as well as the safeguards firms have implemented to support effective oversight, accountability, and compliance. The responses reflect a high level of engagement with these emerging technologies and a strong awareness of both their benefits and associated risks.

Existing RIBO Guidance

RIBO would like to highlight its existing guidance on responsible AI use among RIBO licensees, which outlines key principles and expectations related to the appropriate use of AI within the brokerage context.

Potential Areas for Additional Guidance

RIBO will consider whether additional guidance is needed on acceptable uses of AI and automated quoting tools, minimum expectations for human review, documentation and auditability standards, disclosure considerations, vendor oversight, data governance, and how AI-related controls should be reflected in Plans of Supervision.

Ongoing Monitoring

RIBO will continue to monitor developments in AI and automated decision-support tools and will seek to support responsible innovation while ensuring that supervision remains effective, accountability remains clear, and consumer protection is maintained.

• Strong support for controls related to privacy, cybersecurity, and vendor management, particularly where third-party tools or external data are used.
• Several respondents highlighted systemic risk concerns, noting that AI-driven errors can scale quickly across multiple clients and are more difficult to detect than individual broker errors.

A recurring theme was the need for regulatory clarity, particularly regarding acceptable uses of AI, minimum human oversight standards, documentation and audit expectations, disclosure requirements, and how AI governance should be incorporated into Plans of Supervision, with several respondents noting that uncertainty in these areas is a barrier to adoption and innovation.

Summary of Consultation Responses

• Respondents consistently supported the need for more practical, plain-language guidance, with an emphasis on translating regulatory expectations into operational steps and day-to-day practices.
• Strong demand for expansion of the Principal Broker Handbook, including updated online content, sample Plans of Supervision, audit expectations, and role-specific guidance.
• Broad agreement on the value of real-world examples and case studies, including anonymized disciplinary decisions, audit findings, and common deficiencies to support learning and consistency.
• Respondents emphasized the importance of training and ongoing engagement, including webinars, workshops, certification programs, and targeted education on emerging or complex issues.
• There was strong support for developing tools to support self-assessment, such as audit checklists, competency frameworks, and supervision templates.
• A recurring theme was the value of increased transparency, particularly around enforcement outcomes and regulatory expectations, to support industry-wide learning.
• Respondents supported structured and ongoing dialogue with industry, including advisory committees and engagement with firms of different sizes and operating models.

Consultation Feedback

RIBO thanks respondents for their input on how it can further support the industry in communicating supervision expectations and how RIBO can best support the industry.

Current Communication Initiatives

RIBO acknowledges that clear, accessible, and practical communication is critical to the successful implementation of a principles-based supervision framework. RIBO has undertaken several initiatives to enhance its communication with respondents. These include updates to the Principal Broker Handbook, aimed at improving clarity around roles and expectations, and the recent introduction of a Spot Checks course, which provides additional insight into RIBO’s supervisory and compliance review processes.

Use of Discipline Decisions

RIBO also continues to publish discipline decisions through the RIBO Bulletin. These decisions provide real-world examples that can serve as valuable educational resources for licensees, support greater transparency, and help brokerages better understand how regulatory expectations are applied in practice.

Opportunities to Expand Support

At the same time, RIBO recognizes that there is an opportunity to build on these efforts. Consistent with respondent feedback, there is a clear need to further expand practical guidance and support for Principal Brokers and supervisory staff. This includes the potential development of additional tools and resources, expanded education and training offerings, and more structured opportunities for dialogue with industry participants.

Ongoing Commitment

RIBO remains committed to working with respondents to ensure that supervision expectations are clearly communicated, well understood, and effectively implemented across the industry.