On July 3, the Ontario Ministry of Finance (MOF) published a new consultation paper with respect to the licensing of managing general agents (MGA). The consultation closes on August 17, 2026. 

Background

In 2024, Ontario proposed amendments to the Insurance Act to establish a dedicated licensing framework for life and health MGAs and to grant the Financial Services Regulatory Authority of Ontario (FSRA) associated rulemaking authority over MGAs. To accompany the legislative changes, FSRA then developed a proposed rule establishing standards of practice for recruiting, training, supervising and monitoring prospective agents, including assigned roles and responsibilities to insurers, L&H MGAs and agents.

Due to stakeholder concerns, earlier this year FSRA paused work to finalize the proposed rule and implement the licensing regime, which had originally been targeted for June 1. 

What you need to know about what is proposed

  • The proposed definition of MGA is to be narrowed: To be considered an MGA for licensing purposes, an intermediary must have an agreement directly with an insurer. The agreement must be for the purpose of “facilitating the distribution” of life or accident and sickness insurance. Notably, the proposed amendments distinguish "facilitating the distribution" of insurance from the "selling" of insurance products.

  • The concept of a “sub-MGA” present in the earlier FSRA rule is to be dispensed with. 

  • The activities that shall trigger the requirement to be licensed have also been narrowed. Those supervising or monitoring agents, or screening agents, remain in scope and within the proposed definition of MGA for regulatory purposes. 

  • Exemptions are proposed for licensed insurers (including an officer or employee of an insurer acting on that insurer's behalf) and group-insurance only intermediaries.  

  • The MOF proposes to prescribe by regulation certain activities which, while not triggering the MGA licensing requirements, would be subject to regulation as part of the overall framework.  FSRA would be authorized to establish standards of practice for these prescribed activities which are proposed to include:

    • Recruiting agents or prospective agents.

    • Providing training to agents or prospective agents.

    • Supervising or monitoring the activities of prospective agents.

    • Other activities and functions which may be added to this list by regulation.

  • The MOF is also seeking feedback on whether additional business structures beyond corporations and partnerships should be eligible to apply for an MGA licence, noting that individuals are currently not eligible unless operating under an appropriate business structure.

Looking ahead

Interested parties are invited to submit a comment on the proposed amendments by August 17, 2026.

If you have any questions about this topic, please contact the authors or a member of our Insurance & Reinsurance practice.