RIBO Guidance 004 – RIBO Licensee Requirements and the Take-All-Comers Rule

Purpose

The purpose of this guidance is to ensure brokers understand their responsibilities under the Take-All-Comers (TAC) Rule and RIBO’s expectations of licensees.

Background

In Ontario, auto insurance is mandatory for operating a vehicle. The TAC Rule is designed to ensure fair access to auto insurance for all consumers in Ontario. The TAC Rule provides certain consumer protections by requiring insurers, agents and brokers to:

1. Offer the lowest rate available based on a needs assessment of consumers’ circumstances;
2. Offer their consumers a renewal if they continue to meet that insurer’s eligibility rules; and,
3. Accept all auto insurance business from consumers that meets their available insurer’s approved rules.

The TAC Rule requires that insurers and their intermediaries work together to ensure that consumers are treated fairly.

Scope of the Rule

The TAC Rule applies to all Private Passenger Automobiles (“PPA”) and Individually Rated Commercial Automobiles (“IRCA”).

The Financial Services Regulatory Authority of Ontario (FSRA) does not require insurers to use filed underwriting rules for making decisions with respect to insuring a ‘fleet.’

There are other rules, including the Unfair and Deceptive Acts or Practices Rule and s. 237(1) of the Insurance Act, that apply to automobile fleet underwriting and quotations. For more information, see FSRA’s guidance.

RIBO licensees are responsible for ensuring compliance with the TAC Rule for all of their outsourced activities, contracts, agreements, and any relationships with third parties including aggregators, online quoters, and Broker Management System (BMS) providers.

Impact on Licensees

The TAC imposes several responsibilities and duties on brokers.

Overarching Practice Expectations

Brokers must:

• Obtain and provide quotes from all of their available auto markets.
• Consider multiple factors when providing insurance recommendations. Recommendations should not solely be based on cost.
• Recommend the most suitable policy coverage for the consumer’s needs and offer the lowest quote based on the policy recommendation.
• Be prepared to provide advice to consumers about the risks of declining or reducing coverage. Where a consumer requests the statutory minimum coverage, you must present such a policy and ensure that you inform the consumer of the risks of this option.
• Accept all auto insurance business, including renewals, from consumers that meet the insurer’s filed underwriting rules. Auto insurance coverage can only be refused based upon filed and approved factors that should be made clear in the insurance companies’ underwriting manual.
• Report any known instances of non-compliance with the TAC Rule and this guidance to RIBO.

Quoting Optional Benefits

On July 1, 2026, changes to the Statutory Accident Benefits Schedule (SABS) mean that medical, rehabilitation and attendant care benefits will remain mandatory, while all other accident benefits coverage will be optional. This will allow consumers more flexibility to choose the coverage that best fits their needs and budgets.

As part of these changes, insurers will have the flexibility to bundle certain related coverages together to create a more simplified offer for consumers or offer bundled savings.

Brokers must be aware that consumers may have access to private disability or group plan coverage. Brokers must ensure that they adhere to their licensing restrictions and not cross over to Accident & Sickness advice including analyzing group plan coverages.

Brokers must follow a quoting process that considers potential bundles and quoter limitations, ensuring consumers are informed of all optional accident benefits and given the opportunity to select the benefits and coverage limits they wish to purchase.

Disclosure and Documentation Obligations

Brokers must:

• Disclose the lowest rate: Brokers must inform the consumer of the lowest rate available based on the broker’s consumer needs assessment. If the broker recommends another product, the broker must still disclose the lowest rate available.
• Disclose all available insurers: If requested, brokers must provide the names of all auto insurers they work with by sharing a list or sharing the brokerage’s commission disclosure document.
• Inform consumers of their rights: Brokers must advise consumers that they have the right to request all quote-related information in writing.
• Share all quote-related information: If requested by the consumer, brokers must provide applicants with information to help them understand all available quotes.
• Ensure accessibility of information: Brokers must have the necessary systems and processes in place to provide the requested information promptly.
• Document: All consumer quotes, including reasons for accepting or declining recommended products or rates must be documented. A complete quote log must exist in each consumer file, capturing all available market quotes and related commentary.
• Retain Records: Consumer files should be retained for a minimum of six years. Files may need to be retained for a longer period to ensure compliance with contractual and privacy obligations.

Renewals

RIBO does not require brokers to contact all consumers to provide an updated quote at renewal, although some may opt to do so as a best practice.

Brokers must, however, contact their consumers in advance of their policy renewal date to ensure their existing coverage remains adequate and suitable.

In their communications, brokers can identify and target groups of consumers who may be subject to higher-than-market-average rate increases and invite them to review their existing coverages.

Policy Changes

When a consumer asks for a mid-term policy change or cancellation, brokers are required to explain the relative benefits and costs including any cancellation penalties for making a mid-term policy change.

Portfolio Transfers

Entering into an agreement with an insurer to transfer one or more books of business may violate the Take-All-Comers Rule, the Insurance Act, and could be considered misconduct under the RIBO Code of Conduct and the Registered Insurance Brokers Act.

Unacceptable insurer agreement conditions may include requiring referral to the insurer before binding specific auto accounts due to rating territory or class of use.

Brokers are encouraged to consult the Portfolio Transfer section of the Supplementary Resources for additional guidance and information.

RIBO’s Expectations for Principal Brokers

RIBO expects that Principal Brokers create, develop, and implement TAC processes and guidelines in their brokerage. During a RIBO Spot Check, each brokerage must be able to demonstrate that they:

• Provide staff with the necessary training to ensure that they understand the purpose of TAC procedures and the importance of complying with them.
• Implement effective documentation and monitoring measures, such as record keeping, internal audit procedures and appropriate supervision of licensees and automated systems.
• Have confirmed that automated quoting processes are instantaneous as unjust delays are effectively treated as declining coverage.
• Ensure that all outsourced activities and contracts with third-parties are fully compliant with the TAC Rule (e.g., outsourcing the quoting function to an aggregator).

Relevant Legislation and Rules

The TAC Rule was established by FSRA and applies to insurers, agents and brokers. FSRA has published its own guidance for its licensees and its expectations for fair treatment of consumers. For more information, please refer to FSRA’s webpage.

Brokers are subject to legislative requirements found in both the Compulsory Automobile Insurance Act and the Insurance Act that is relevant to their compliance with the TAC Rule. For example, Section 230 (1) of the Insurance Act provides that: A broker shall provide to an applicant for insurance the names of all the insurers with whom the broker has an agency contract relating to automobile insurance and all information obtained by the broker relating to quotations on automobile insurance for the applicant.

Guidance published on December 11, 2025.