RIBO Guidance 005 – Sole Occupation Requirement for Individual Licensees

Ontario Regulation 991, Section 5 outlines the registration requirements for an individual. It states that the “only business or employment” of an individual be that of an insurance broker, or an insurance broker/life agent. The regulation also provides that the Qualification & Registration Committee (“QR Committee”) may grant exemptions from the “only business or employment.” This means that any other employment or business that is not of an insurance broker or a life agent requires an exemption from the QR Committee.

The primary purpose of the section is to prevent real or perceived opportunities for coercion and conflict of interest with respect to insurance consumers.

Secondary Business Applications

An application for a Secondary Business Exemption must be made to the QR Committee for any other business involvement or employment by submitting a letter of request and completing a secondary business exemption form. A letter from the Principal Broker outlining the qualifications of the individual and supporting the request for the exemption must accompany the application. An individual must be granted an exemption from the QR Committee prior to any involvement in a secondary occupation.

Any change of employment would require support from the Principal Broker of the hiring brokerage, and it must be submitted to RIBO.

To improve transparency and address common questions regarding the sole occupation requirement, the QR Committee has approved lists of QR Review Required & Incompatible Occupations and Approved Occupations.

The approved list of occupations will automatically be granted an exemption once the required application and paperwork are received and provided that:

  1. The occupation appears on the approved list, and
  2. It falls within the parameters set by the QR Committee.

If the occupation does not fall within the parameters set out, it will be referred to the QR Committee for additional review.

QR Review Required & Incompatible Occupations (including licensed occupations) must be referred for review by the QR Committee.

The Committee reviews each secondary occupation exemption request on the individual merits and facts of each individual request.

Certain occupations have been deemed to be an unmanageable conflict of interest and therefore incompatible with the insurance business profession. As such, these secondary business applications will be refused.

Please note, even in cases where the occupation is deemed “incompatible” with the insurance broker profession, licensees may still submit an application for consideration by the Committee.

Decisions will in no way be binding in the event of a similar occurrence and may be considered differently based on the facts and merits of the case including (but not limited to):

  • Conflict of interest
  • Coercion or undue influence
  • Duties while acting as a broker
  • Number of hours involved
  • Amount of remuneration
  • Along with original requirements, these requests will also require additional letters from the individual and Principal Broker outlining how both will manage potential undue influence and conflicts and potential conflicts with respect to insurance contracts.

In all cases, whether you are newly licensed or have been a licensee for several decades, you must submit a secondary business exemption request to licensing@ribo.com before you begin your secondary occupation. Access the request form and see what supporting documents are required.

  • New licence applications will be accepted only after the exemption request has been granted.
  • Licensed individuals must wait for their exemption request to be granted, prior to any involvement in a secondary occupation.

RIBO’s QR Committee has approved lists of approved occupations, as well as lists of incompatible occupations and occupations requiring QR review, to improve transparency and address common questions regarding the sole occupation requirement.

Once an individual submits the required secondary business exemption application and paperwork for other business(es) falling under the approved list of occupations, they will automatically be granted an exemption provided that:

  1. The occupation appears on the approved list, and
  2. It falls within the parameters set by the QR Committee.

If the occupation does not fall within the parameters set out by the QR Committee, it will be referred to the QR Committee for additional review.

Below are some industries and examples of approved occupations. (Some occupations may require conditions to be placed on the licence.) Other secondary occupation exemptions may still be approved by the Qualification & Registration Committee.

Construction and Manufacturing

  • Staff Level Labourers
  • Warehouse Workers

Finance

  • Financial Services Regulatory Authority of Ontario (Life and A&S Agents)
  • Certain Financial Products (Life Insurance Products):
    • GICs
    • RRSPs
    • RESPs
    • Mutual Funds

Hospitality and Tourism

  • Travel Industry Council of Ontario Licensee
  • Uber/Lyft Drivers
  • Security Officers
  • Servers
  • Hostess
  • Bartenders
  • Cook/Kitchen Staff
  • Disc Jockeys
  • Cleaners
  • Ride Operators
  • Tourist Operators
  • Wilderness Guides
  • Influencer/Blogger
  • Demonstrators

Public Administration

  • Reeves, including City Counsellors (Some occupations may require conditions to be placed on the licence.)

Public Safety

  • Firefighters including volunteers (Some occupations may require conditions to be placed on the licence.)

Instructors

  • Insurance Course Instructors
  • Coaches
  • Fitness Instructors
  • Music Teachers
  • Dance Instructors
  • Arena Employees

Professional and Technical Service

  • Professors (See note on certified teachers.)
  • Tutors
  • Transcribers
  • Translators
  • IT Professionals (Excluding Client-Facing Sales/Advisory Services)
  • Income Tax Preparers

Retail

  • Cashiers
  • Customer Service Representatives
  • Makeup Artists
  • Stockers
  • Aestheticians
  • Hairdressers

Red Seal Trades

  • See Approved Red Seal Occupations List (Appendix)

Small Businesses

  • Photographers
  • Models
  • Dog Walkers
  • Birthing Coaches
  • Crafts
  • Fashion
  • Food Product
  • Home Decorators
  • Adult Entertainers
  • Bookkeeping/Accounting for Family-Owned Business (must not be involved in day-to-day operations)
  • Home Party Sales (e.g., health and wellness products and Tupperware sale)

Canadian Forces

  • Cadet Organizations Administration Training Service
  • Primary Reserve

Approved Licensed Occupations List (with Conditions and Limitations)

Below is a list of regulatory bodies along with their conditions and/or limitations.

Regulated Health Professions (Category 1)

  • Must attest that they have notified their other regulatory body of their RIBO licence or application for RIBO licensing.

College of Early Childhood Educators

  • Must attest that they have notified their other regulatory body of their RIBO licence or application for RIBO licensing.

Law Society of Ontario, Paralegal And Lawyer

  • Restricted to providing legal advice to the insurance brokerage you are licensed under only, any outside employment would be considered incompatible and prohibited. (Undertaking required.)

Professional Geoscientists Ontario

  • Must attest that they have notified their other regulatory body of their RIBO licence or application for RIBO licensing.

QR Review Required & Incompatible Occupations must be referred for review by the QR Committee. The Committee reviews each secondary occupation exemption request on the individual merits and facts of each individual request.

Certain occupations have been deemed to be an unmanageable conflict of interest with RIBO licensing and the secondary business application will be refused. Please note, even in cases where the occupation is deemed to be an unmanageable conflict of interest, licensees may still submit an application for consideration by the Committee.

A. Incompatible Occupations List

Below is a list showing industry/trade and examples of occupations that require QR Committee approval. Please note that this is not a comprehensive list, and any other occupations may require review by the Committee.

Finance

  • Loan and Trust Company Employees
  • Bank Employees
  • Loan Trustees

Health Care

  • Regulated Health Professions (Category 2)

Public Administration

  • Mayors
  • Members of Parliament
  • Members of Provincial Parliament
  • CRA Employees
  • Government Employees (including municipal/provincial/federal governments, crown corporations, government agencies/boards/commissions)

Public Safety

  • Police Officers
  • Auxiliary Constables

Professional and Technical Service

  • IT Client-Facing Sales/Advisory Services
  • Home Inspectors/Appraisers
  • Immigration Consultants
  • Officers of a Trade Union/Association
  • Sales/Advisory Services

Transportation/Automotive Businesses

  • Trucking Including Truck Drivers
  • Tow Truck Drivers
  • Employees and Owners of Dealerships and Mechanics

B. Incompatible Licensed Occupations List

Below is a list of regulatory bodies and licensed professions along with their RIBO licence conditions.

Canadian Investment Regulatory Organization

  • QR Review Required

Chartered Professional Accountants of Ontario

  • QR Review Required

College of Veterinarians of Ontario

  • QR Review Required

Financial Services Regulatory Authority of Ontario

  • General Insurance Agents (OTL Licence) – Not Allowed
  • Adjusters – Not Allowed
  • Mortgage Agents – Not Allowed
  • Mortgage Brokers – Not Allowed

Ontario Association of Architects

  • QR Review Required

Ontario College of Teachers

  • QR Review Required

Ontario Motor Vehicle Industry Council

  • Not Allowed

Ontario Securities Commission

  • Investment Dealers – Not Allowed

Professional Engineers Ontario

  • QR Review Required

Red Seal Trades (Category 2)

  • QR Review Required

Real Estate Council of Ontario

  • Not Allowed

Regulated Health Professions (Category 2)

  • Not Allowed

RIBO recognizes that volunteerism serves an important role in connecting licensees to their communities, promoting self-fulfillment, and building trust in the insurance industry. To not discourage volunteerism, RIBO does not require licensees to request secondary business exemptions for most unpaid and paid volunteer activities.

This does not reduce or eliminate a licensee’s duty to avoid and mitigate conflicts of interests as required by the section 7.14 and 7.14(1) Code of Conduct found in Regulation 991. Volunteering can create conflicts of interest between your duty as a licensed professional and the organizations you volunteer for.

Secondary business exemption requests would however still be required for individuals serving in board of director or officer roles (paid/unpaid) for the following types of corporations:

  • Insurance Companies;
  • Any financial services institutions, including banks, credit unions, wealth management or mortgage brokerages, etc.;
  • Regulated professions;
  • Transportation Corporations; and,
  • Condominium corporations.

Principal Brokers are encouraged to develop policies and guidelines regarding volunteerism as part of their supervisory functions to manage any potential conflicts of interest. The Code of Conduct is an excellent resource to review as you develop your policies as it outlines your responsibilities as a licensee.

The following sections are the most relevant resources as it relates to another business or occupation, including volunteering:

  • Paragraph 7 – Duty to Client Where Broker Has Another Business
  • Paragraph 7.1 – Disclosure of Facts Indicating Potential Conflicts of Interest

Board of Directors

Insurance brokers may be asked or want to join a board of directors to bring the broker’s perspective and their expertise to discussions. This can create a conflict of interest as you have conflicting fiduciary duties to the brokerage and the organization that you are a board member of.  If you serve on a board of directors for any organization, you may not directly sell insurance to that organization. Instead, you must either refer the organization to a different broker at your brokerage or to another brokerage to purchase insurance.  This is not a conflict that can be managed through disclosures or other regulatory tools. If you have sold a policy to the organization and you currently serve on the board of directors, refer the client file to another broker at your brokerage at renewal.

Regulated Health Professions (Category 1)

Health College Approved Occupations

Category 1 regulated health professionals must self-attest they have disclosed that they have applied or have a RIBO licence to their regulator.

  • College of Dental Hygienists of Ontario
  • College of Dental Technologists of Ontario
  • College of Denturists of Ontario
  • College of Dietitians of Ontario
  • College of Audiologists and Speech-Language Pathologists of Ontario
  • College of Homeopaths of Ontario
  • College of Kinesiologists of Ontario
  • College of Massage Therapists of Ontario
  • College of Medical Laboratory Technologists of Ontario
  • College of Medical Radiation and Imaging Technologists of Ontario
  • College of Midwives of Ontario
  • College of Naturopaths of Ontario
  • College of Nurses of Ontario
  • College of Occupational Therapists of Ontario
  • College of Opticians of Ontario
  • College of Physiotherapists of Ontario
  • College of Respiratory Therapists of Ontario
  • College of Traditional Chinese Medicine Practitioners and Acupuncturists of Ontario

Regulated Health Professions (Category 2)

Health College

  • Royal College of Dental Surgeons of Ontario
  • College of Chiropodists of Ontario
  • College of Chiropractors of Ontario
  • College of Optometrists of Ontario
  • College of Physicians and Surgeons of Ontario
  • College of Psychologists of Ontario
  • College of Registered Psychotherapists of Ontario
  • Ontario College of Social Workers and Social Service Workers
  • Ontario College of Pharmacists

Red Seal Trades (Category 1)

Red Seal Trades (Category 1) Approved Occupations

  • Agricultural Equipment Technician
  • Appliance Service Technician
  • Baker
  • Boilermaker
  • Bricklayer
  • Cabinetmaker
  • Carpenter
  • Concrete Finisher
  • Cook
  • Drywall Finisher and Plasterer
  • Floorcovering Installer
  • Gasfitter – Class A
  • Gasfitter – Class B
  • Hairstylist
  • Heavy Duty Equipment Technician
  • Heavy Equipment Operator (Dozer)
  • Heavy Equipment Operator (Excavator)
  • Heavy Equipment Operator (Tractor-Loader-Backhoe)
  • Industrial Mechanic (Millwright)
  • Instrumentation and Control Technician
  • Heavy Equipment Operator (Tractor-Loader-Backhoe)
  • Industrial Mechanic (Millwright)
  • Instrumentation and Control Technician
  • Ironworker (Generalist)
  • Ironworker (Reinforcing)
  • Ironworker (Structural/Ornamental)
  • Landscape Horticulturist
  • Machinist
  • Metal Fabricator (Fitter)
  • Mobile Crane Operator
  • Painter and Decorator
  • Powerline Technician
  • Sheet Metal Worker
  • Sprinkler Fitter
  • Steamfitter/Pipefitter
  • Tilesetter
  • Tool and Die Maker
  • Tower Crane Operator
  • Welder

Red Seal Trades (Category 2)

Red Seal Trades (Category 2) Occupations Requiring Q&R Approval

  • Auto Body and Collision Technician
  • Automotive Refinishing Technician
  • Automotive Service Technician
  • Construction Craft Worker
  • Construction Electrician
  • Glazier
  • Industrial Electrician
  • Insulator (Heat and Frost)
  • Lather (Interior Systems Mechanic)
  • Motorcycle Technician
  • Oil Heat System Technician
  • Parts Technician
  • Plumber
  • Recreation Vehicle Service Technician
  • Refrigeration and Air Conditioning Mechanic
  • Roofer
  • Transport Trailer Technician
  • Truck and Transport Mechanic

Guidance published on February 6, 2026.

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