Insurance advisors licensed elsewhere in Canada can now practice in Ontario within days, not months, under new rules that took effect last summer.
Bill 2, the Protect Ontario Through Free Trade Within Canada Act, 2025, received Royal Assent on June 5, 2025. The legislation amends the Ontario Labour Mobility Act, 2009 and enacts the Ontario Free Trade and Mobility Act, 2025, establishing new rules for interprovincial trade in services and labour mobility.
The Financial Services Regulatory Authority of Ontario began implementing the new labour mobility licensing process on January 1, 2026. FSRA oversees licensing for mortgage brokers and agents, life and health insurance agents, property and casualty insurance agents, insurance adjusters and health service providers.
Regulators now have 30 calendar days to make a decision once they receive everything they need from an applicant. That counts weekends and holidays, a shift from the old system that used business days. The clock starts ticking only after the application is complete.
Within 10 business days of receiving an application, regulators must send back a confirmation that spells out whether anything is missing. When they make their final call, they have to explain their reasoning if they plan to deny certification or attach conditions. Applicants also get information about how to challenge the decision.
The legislation introduces a six-month deemed certification period for prescribed regulated occupations. Eligible individuals with an equivalent licence from other Canadian jurisdictions get what FSRA calls an "express lane" to licensing. Once they submit their out-of-province certificate and prescribed information, they get a receipt within 10 business days. That receipt grants them six months of automatic certification to practice while their full application moves through the system.
During those six months, out-of-province advisors follow the same rules as everyone else licensed in Ontario. The temporary certification is a one-time offer, and regulators will specify which occupations qualify. Financial services professionals are deemed certified and able to start working once FSRA confirms receipt of a complete "as of right" application, including all required documents.
Regulators cannot demand that advisors certified elsewhere complete additional training, rack up more experience, or pass new exams before getting their Ontario license. The law leaves room for regulations that could spell out other requirements that are off limits.
Every requirement that regulators impose on out-of-province applicants must now appear on a public website. The disclosure requirement aims to eliminate surprises for advisors trying to navigate the system.
Regulators will have to file reports about labour mobility issues with the provincial minister responsible for coordinating these matters. Missing those reporting deadlines can result in compliance orders.
Bill 2 creates a new offence for making false representations. Any person who knowingly lies to meet requirements for deemed certification faces fines up to $25,000 for a first offence and up to $50,000 for subsequent offences.
The bill also creates the Ontario Free Trade and Mobility Act, 2025, setting up a system where the province can designate other Canadian jurisdictions as partners in mutual recognition. Advisors licensed in those partner jurisdictions and in good standing back home become entitled to Ontario authorization.
The legislation includes immunity provisions, extinguishing causes of action against the Crown, regulatory authorities, and related officials arising from the enactment or implementation of the Act.
Applicants who do not meet the criteria for the new labour mobility licensing process can still apply through the standard out-of-province licensing process. Most provisions came into force on July 1, 2025, with the offence provision subject to proclamation by order of the Lieutenant Governor in Council.
