The purpose of this guidance is to inform individual and firm licensees of RIBO’s expectations regarding professional conduct for social media and the use of online review platforms. It interprets existing Code of Conduct obligations in the context of licensees’ online conduct more generally.
Social media can be an important tool for conducting business. It can be used for advertising, education, and social networking opportunities among other uses. Many of these uses can enhance trust in the profession. Social media use also carries professional conduct, regulatory and legal risks. These risks ought to be carefully managed to maintain public trust and confidence in the profession.
This guidance applies to social media use for insurance brokering professional activities – not for personal use. RIBO does not provide guidance to licensees on personal social media use as it relates to freedom of expression. Take note, however, that personal social media activities may be scrutinized and used as part of a complaints or discipline proceeding if there is a sufficient nexus connecting the conduct of the licensee to the profession.
For the purposes of this guidance, social media refers to online, public‑facing platforms that enable visual, video, and/or written content to be shared with or viewed by multiple persons. This includes activities such as liking or reacting to posts, sharing or reposting content, creating polls, posting comments, and uploading images or videos.
This definition includes public‑facing advertising, marketing, and promotional activity. It does not extend to private, one‑to‑one communications.
Examples of social media include Facebook, Instagram, LinkedIn, and YouTube. Of note, these examples are not meant to be an exhaustive list of social media tools or platforms that exist at the time of writing this guidance. Any reference to named social media platforms is intended solely to provide examples of commonly used communication channels and does not constitute endorsement, approval, or affiliation. Licensees are solely responsible for ensuring that their use of any platform complies with applicable legislation, regulations, and RIBO requirements.
The guidance does not extend to business communications or use of messaging platforms such as iMessage or WhatsApp to communicate with clients. Licensees should refer to their employee manual or Principal Broker if they have any questions about the use of these platforms to support their business.
The Summary of Requirements is based on Regulation 991 made under the Registered Insurance Brokers Act.
It is common practice for licensees to maintain a social media presence to draw in new business. In doing so, licensees must consider the following:
All licensees have a duty to encourage public respect and trust in the profession and to conduct themselves with courtesy and good faith.
This means debates, commentary, and criticism levied against fellow licensees, insurance industry professionals, government, regulatory bodies, including RIBO, and members of the public must be respectful and factual.
Licensees should avoid social media use that may be construed as inflammatory, such as making false and/or misleading allegations, insulting one another, and posting verifiably false information.
Licensees posting educational content regarding insurance or conducting licensed activities on social media must take reasonable steps to ensure that all information provided is accurate and factual.
Licensees should take extra precautions and care in providing educational content on insurance lines they lack substantial knowledge in, as this advice can influence a consumers’ financial decision-making process, especially when the information comes from a licensed professional.
The extent to which licensees may conduct business over social media platforms is not unlimited. Licensees must not give the impression that members of the public can obtain quotes, advice, or submit routine client information through social media such as applications or policy changes (e.g., address changes, vehicle substitutions, etc.).
In situations where a potential client requests a quote via social media, licensee interactions should be transitioned to the designated platform for the firm’s business communications.
Reminder: Only an individual who is sponsored or acting as an employee can use social media to advertise insurance broker services or provide personalized advice pursuant to section 8.1 (a) of RIBO By-Law 3.
This should not be misconstrued as prohibiting publishing general information, such as (but not limited to) discussions on how insurance may apply to specific scenarios, insurance concepts, and educational content.
Principal Brokers should establish and maintain an internal approval process to ensure all online advertising (including advertising on the brokerage’s website, Google, social media, etc.) meets regulatory requirements, including the following:
With the growth of Artificial Intelligence (“AI”), it is easier than ever to generate content (e.g., posts, images). However, the content generated by AI has dubious copyright protection. Depending on the data it was trained on and the similarities generated content could have with existing publications, there may be copyright challenges to using AI-generated material on social media. Exercise caution when choosing to use AI to assist in creating marketing materials and communications.
AI-generated content used in advertising must be vetted by either the Principal Broker, their delegate, or through a process that verifies that the content is accurate and factual, and in line with any of RIBO’s regulatory requirements and other applicable legislation.
Principal Brokers are responsible for ensuring that all licensees under their supervision act in accordance with the Registered Insurance Brokers Act, regulations, RIBO By-Laws, as well as related RIBO guidance and insurance regulations more generally. This responsibility extends to firm and individual licensees’ professional social media use.
Principal Brokers should include, as part of their Plan of Supervision, a section on professional social media use by the firm and licensees.
Principal Brokers and licensees are responsible for ensuring that all information received from a client is confidential. Licensees must not share client information on social media in any format without prior authorization and informed consent from the client and/or must make substantive efforts to anonymize the client’s information.
RIBO does not prescribe methods of complying, given how varied social media use can be across firms. Principal Brokers should be able to reasonably demonstrate how they monitor firm advertising on social media to RIBO upon request.
As part of the Plan of Supervision, Principal Brokers should develop a social media policy to identify whether social media can be used by individual licensees to advertise their professional services.
If permitted, the Principal Broker should establish clear rules and procedures governing how licensees may conduct themselves if they are holding out as an insurance broker on social media platforms, including ensuring compliance with the Registered Insurance Brokers Act, its regulations, and RIBO By-Laws.
This could include setting clear guard rails for advertising and communications using social medial tools, including requiring that the individual’s licence number appears on their social media profile and whether customer interactions outside the firm’s approved communication systems (such as company email) are permitted. The rules should also clearly explain how these communications are recorded in clients’ files. RIBO has developed a Sample Checklist for Individual Licensees on Using Social Media Professionally (see the bottom of this guidance), which could be incorporated within any firm’s social media policy.
Licensees should receive training on the firm’s social media policy before being permitted to use social media in a professional capacity.
This training should occur on a scheduled basis and be delivered whenever specific situations arise, such as notable misuse of social media.
The Principal Broker may wish to appoint an individual or team to monitor social media use by all persons working on behalf of the firm. This individual or team can also act as an important resource for any questions regarding compliance with RIBO’s legislation or other applicable legislation, and recommend additional training or policy and procedure development if required.
The Principal Broker should implement policies for managing any client information posted on social media to ensure compliance with confidentiality and consent requirements.
Principal Brokers should educate their employees about obtaining informed consent from clients before using their information. An example of an informed consent policy outline is as follows:
Alternatively, licensees may de‑identify client information. If there are concerns that the client could be identified, licensees should seek the client’s informed consent.
Online reviews play an important role in how consumers choose where to obtain insurance services. Because many consumers treat online reviews similarly to personal referrals, the credibility and authenticity of these reviews directly influence their decision‑making.
Reviews can take many forms, including written comments, star ratings, like/dislike buttons, videos, and other digital formats. When reviews are manipulated, directly or indirectly, consumers can be misled about the quality of service they can expect, ultimately undermining fair competition and distorting the marketplace.
Review manipulation is any act, direct or indirect, that maliciously alters, distorts, or misrepresents the ratings, reviews, or testimonials associated with a licensee or competitor on any review platform or website that displays reviews or ratings.
This includes actions taken by the licensee, by employees, by contractors, or by third‑party marketing agencies acting on the licensee’s behalf.
RIBO considers review manipulation to be a deceptive and misleading marketing practice that is explicitly prohibited as an act of misconduct by section 15 (1), 1. of Regulation 991.
Review farming is a subset of review manipulation that refers to the incentivizing, buying, and selling of reviews, or fabrication of fake consumer reviews.
Review gating includes filtering reviews to prevent members of the public from having the ability to access certain reviews, e.g., only positive reviews show on websites. RIBO considers these activities to be false and misleading forms of advertising.
Sections 14(1), 14 (9), 14(11) of the Code require brokers to act with integrity—both as individual professionals and as representatives of the broader industry.
Review manipulation and review farming more generally are fundamentally incompatible with this obligation because it involves unfair and dishonest conduct, whether carried out for personal gain or to disadvantage a competitor. Such behaviour erodes trust between the broker and the consumer. If the client later discovers that reviews were manipulated, they may question the reliability of the licensee’s advice and services. This not only damages the individual licensee’s reputation but also undermines confidence in the industry, as consumers may assume the practice is widespread.
RIBO reminds licensees to exercise caution when responding to reviews. Unprofessional responses may be found to breach the duty to encourage public respect for the profession if the statements made are unfounded or inappropriate.
Best Practices
Document
Licensees who solicit consumer reviews should maintain a documented process for receiving, assessing, and responding to negative reviews or feedback. When responding to any review, licensees must remember that they are acting in a professional capacity and are obligated to address consumer concerns appropriately and in accordance with RIBO’s conduct standards.
Education
Firms should also ensure that all employees involved in soliciting or monitoring reviews receive training on how to properly identify, escalate, and respond to negative feedback.
Prohibited Practices
Licensees must avoid practices that intentionally suppress negative reviews or artificially inflate ratings. Review manipulation includes, but is not limited to, the following actions:
Examples of Review Manipulation
What Is Not Prohibited?
RIBO does not consider the following examples to be review manipulation:
This checklist provides examples of individual licensees’ responsibilities and outlines some best practices for using social media in a professional capacity. Firms may wish to incorporate a checklist for individuals as part of an Employee Handbook or social media policy.
Guidance published on June 1, 2026.