FSRA auto reform accident benefits optionality Q&A for Insurers

*What should insurers and/or their intermediaries communicate to fleet owners and operators when changes are requested to optional accident benefits?

Insurers and/or their intermediaries should discuss the changes requested with fleet owners and operators and their potential implications for drivers and employees. Fleet owners and operators should understand the optional accident benefits coverages available, who may be eligible for these benefits, and that eligibility may vary depending on the specific circumstances of a claim. Insurers and/or their intermediaries should also encourage fleet owners and operators to communicate relevant coverage information to drivers and employees to promote informed insurance decisions. Clear and timely communication can help avoid misunderstandings about the scope of available benefits.

*What are FSRA’s expectations if optional accident benefits are removed or reduced under a rideshare fleet policy?

As rideshare fleets use non-standard forms, FSRA requests that insurers notify us if optional accident benefits are removed or coverage reduced under a rideshare fleet policy. This information will support FSRA’s ongoing monitoring of the implementation and evolution of SABS optionality in the industry to help better understand potential impacts.

*What is the difference between a named insured, a deemed named insured, and a listed driver for optional accident benefits?

A named insured is identified as an insured under the policy. A listed driver is identified in the policy as a driver of the insured automobile. A deemed named insured is a person who may be treated as a named insured under s. 3(7)(f) or (g) of the SABS where the legislative requirements are met.

This distinction matters because, under s. 2(1.0.4) of the SABS, optional accident benefits may be available to named insureds, their spouses and dependants, and listed drivers. An individual that is deemed to be a named insured is eligible to receive accident benefits as if that person is a named insured. Whether a person is a deemed named insured is a fact-specific determination based on the circumstances of each case and the applicable SABS provisions. A person may be both a listed driver and a deemed named insured.

If a customer qualifies for multiple limits for the same Accident Benefits coverage (e.g., $400 under their own policy and $1,000 under their spouse’s policy for income replacement), which limit applies when they make a claim?

FSRA expects insurers to treat customers fairly and in accordance with their rights under the OPCF 47R, ensuring that customers receive the level of coverage available to them under the policy for which they are eligible and under which they have elected to claim benefits.

Can an OPCF 47R endorsement be added more than once to the same policy when there are multiple vehicles?

The OPCF 47R is a policy‑level endorsement, but it provides flexibility for insurers to include vehicle‑specific information (such as vehicle IDs) when appropriate. Insurers should assess how applying the endorsement across multiple vehicles aligns with their rating rules, underwriting guidelines, and operational processes. Different insurers may take different approaches depending on their system design and product structure.

FSRA allows flexibility in how insurers implement the OPCF 47R, provided that:

• customers are treated fairly
• the insurer’s approach is transparent
• customers have access to the highest level of coverage available to them under the policy for which they are eligible and under which they have elected to claim benefits

Do the changes taking effect on July 1, 2026, apply to all customers, or only to new business?

The changes effective July 1, 2026, apply to all customers.

As of this date, all Accident Benefits, except medical, rehabilitation, and attendant care benefits will become optional.

Optional accident benefits only apply to:

• the named insured
• the spouse of the named insured
• dependants of the named insured and of the named insured’s spouse
• persons listed as drivers of the insured automobile

Insurers are encouraged to ensure that all drivers are listed on the vehicle/policy to support clarity and transparency.

Do insurers need to add OPCF 47R as of July 1st, 2026, for all existing business?

No. On July 1, 2026, FSRA does not require insurers to add the OPCF 47R immediately to any policy effective before July 1, 2026. For these policies, the endorsement is added to reflect midterm changes to Optional Accident Benefits prior to renewal or when the policy renews.

What is the expectation for customer communications prior to the July 1, 2026, changes taking effect?

Insurers and their intermediaries must communicate with customers in a clear, transparent, and fair manner to build awareness of the upcoming July 1, 2026, Accident Benefits changes. Because the reforms apply to all customers as of July 1, 2026, existing policyholders may wish to review or adjust their Accident Benefits selections before their renewal date. Early communication helps ensure customers understand their options and can make informed decisions. Insurers are encouraged to use efficient and cost‑effective methods such as digital channels, coordinated messaging with distributors, and other proactive outreach. These communications should supplement, not replace, the reform information included in the policy renewal package.

*How should insurers continue communicating with customers about optional accident benefits?

Insurers and/or their intermediaries should communicate with customers in a clear, transparent, and fair manner to help them understand their optional accident benefit choices, supporting informed decision making based on individual needs and circumstances.

Will FSRA reject an insurer’s filing if they decide not to offer each coverage individually?

No. Referring to the communication from FSRA dated November 28, 2024, offering each of the nine new optional coverages individually is a preferred or ‘supported practice’. Insurers should decide which coverages they want to offer individually or through bundles based on their understanding of consumer needs while delivering on the promise of more choice for consumers. For example, bundling coverages together that have a very low technical cost may make sense for insurers and consumers.

Can an insurer only offer bundles?

If it’s clear that bundles align with consumer needs and offer sufficient choice, FSRA will allow it. Customers must be able to decline higher cost coverages irrespective of the insurer’s bundle options. If an insurer proposes only one bundle—for example, all nine coverages offered as a bundle—this does not deliver on the policy intent to offer more choice.

Will FSRA or the government be giving more direction to insurers on bundles?

No. Insurers may decide to bundle certain related coverages together to create a more simplified offer for consumers or offer bundled savings. FSRA expects that bundles will vary between insurers. New coverage bundles and limits should be based on evidence of consumer needs.

Can an insurer file for different coverage limits?

Yes, insurers may file for new or additional coverage limits. If an insurer wants to begin offering lower or higher limits they may file accordingly. However, existing policies must be renewed with the same coverages and limits as the expiring policy unless the customer agrees to a change in writing.

Do insurers have to offer existing coverage limits to new business?

In the accelerated filing path, yes, you are required to offer all existing limits to new business. In the non-accelerated filing path, insurers need to provide a rationale and supporting evidence for changes to existing limits for FSRA’s consideration.

If insurers introduce a dollar limit for coverages that currently have no specified limit (e.g., visitors’ expenses, personal items), does this disqualify them from using the accelerated filing path?

As of July 1, 2026, coverages such as Expenses of Visitors and Damage to Personal items are to be provided for “reasonable and necessary” expenses up to the defined maximum. Insurers may describe this limit as "unlimited", "no limit", or "all reasonable expenses", etc.

The benchmark costing analysis was based on an unlimited amount being treated as a fixed limit. Therefore, insurers who maintain this approach, by using any of the terms above, remain eligible for the accelerated filing path. However, insurers who propose a specific dollar limit must provide actuarial or other supporting evidence for that limit and must pursue the non-accelerated filing path.

Can an insurer file for lower limits than current ones? Example, income replacement of $300/week.

Insurers have the flexibility to offer various benefit limits if the options are supported with evidence of consumer need provided that current limits are offered.

Can insurers/agents/brokers recommend optional AB coverage when quoting new business?

For new business, insurers may quote as appropriate including both mandatory and recommended optional coverages or bundles. New business processes should be transparent for the customer:

• it should be clear which coverages are optional on the quote/offer
• if transacting digitally, consider ways of making it easy for the customer to add/remove optional coverages without necessarily speaking with an agent or broker
• the premium for each optional coverage or bundle should be clear on the quote
• each optional coverage should be briefly explained in plain language such that the customer can assess whether they need that coverage
• if customers are unsure whether they need an optional coverage, support should be available to help them make a reasonable choice based on their profile
• whether a coverage is recommended or not on the quote/offer page, customers should be aware of all the available optional coverages and limits offered by the insurer

Can an insurer implement a time limit on how long customers can continue renewing on pre-July 2026 coverages and limits before transitioning to post July 2026 offerings?

There is no time limit. Expiring policies must renew with pre-July 2026 coverages and limits until the consumer agrees to make changes in writing as per SABS regulation.

Can an existing customer buy-back to pre-2026 coverages and limits if they had opted out?

If a renewing customer chooses to opt out, they will be subject to the post-July 2026 coverages, limits, and bundles available.

Can we bundle new optional coverages with the current optional coverages, or is it only for the new optional coverages?

Insurers have the flexibility to bundle coverages based on evidence of consumer need. Rates and rules for bundles will need to be filed for FSRA’s review and approval.

Should the optional accident benefits and the applicable bundles be offered at a policy or risk level?

Insurers may wish to consider their current rate & risk classification to decide what is appropriate for them and file accordingly.

What is the expectation when completing vehicle additions or substitutions after July 1, 2026, on policies that have not yet renewed? Are these policy changes subject to accident benefit optionality or existing coverage options and limits until renewal?

SABS optionality should be available to all customers starting July 1st, 2026. If a customer requests options before their renewal date (including at the time of vehicle additions or substitutions), a process must be in place to provide optionality. FSRA will not dictate how you should manage this. You can work within your systems and operational constraints provided you remain transparent and fair to your customers.

In addition to offering caregiver benefit and housekeeping and home maintenance benefit on “an impairment” basis (catastrophic and non-catastrophic), can an insurer offer catastrophic only coverage for new business?

Yes, in addition to offering “an impairment” as required per the SABS regulation, an insurer can offer catastrophic only coverage for caregiver benefit and housekeeping and home maintenance benefit in alignment with s. 28 (1.1) of the SABS.

What changes are being made to Caregiver and Housekeeping and Home Maintenance benefits as of July 1, 2026?

There are several changes applicable to caregiver and housekeeping and home maintenance benefits as of July 1, 2026. Please refer to the summary below:

The definitions of an “impairment” and “catastrophic impairment” are not affected by the July 1, 2026, changes (please refer to the SABS for the applicable definitions).

What are the new offering requirements for Caregiver and Housekeeping and Home Maintenance benefits for new business quoting?

Insurers and their intermediaries should assess product suitability and customer needs when presenting options for Caregiver, Housekeeping, and Home Maintenance benefits. For all new business quotes effective on or after July 1, 2026, insurers are required to offer the legislated standard of all impairment for these coverages. Because it provides broader protection, the premium for all impairment will be higher than for catastrophic impairment only. Not all insurers will offer a catastrophic impairment-only buy down; however, those that do may present it when appropriate based on customer need.

If an insurer chooses to default a quote to a single option, that default must be the legislated all impairment option. Insurers may also choose to display both "all impairment" and "catastrophic-impairment-only" options or allow customers to actively select the option that best suits their needs.

How will existing customers’ Caregiver and Housekeeping and Home Maintenance benefits transition at renewal after July 1, 2026?

On or after July 1, 2026, all existing policies will renew with the same coverage as they had prior to July 1, 2026, until the customer elects to make changes. Customers must be made aware that Caregiver and Housekeeping and Home Maintenance have become optional and that new standards have been established.

They have three possible choices after July 1, 2026:

• keep the same level of coverage
• choose the new standard coverage which applies to all “impairment”
• decline (opt-out) Caregiver, or Housekeeping and Home Maintenance optional coverages entirely

Note that a small number of customers may already have purchased enhanced coverage to include both catastrophic and non-catastrophic impairments.