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Executive summary
The Financial Services Regulatory Authority of Ontario (FSRA) is an independent regulatory agency established to improve consumer protection in Ontario. FSRA promotes high standards of business conduct by regulating financial services sectors, including the Financial Planners and Financial Advisors sector.
Educating life insurance entities on title protection
As part of the 2025-2026 Financial Planners and Financial Advisors Supervision Plan, FSRA continued its education initiative to raise awareness about the Financial Professionals Title Protection Framework and address uncredentialed title use in the Life and Health Insurance sector. FSRA engaged nine (9) insurers and managing general agents (MGA), representing slightly more than one-half of all licensed insurance agents in Ontario, to communicate its expected outcomes under the title protection framework and gather insights on the entities’ compliance efforts.
Key findings include the following:
- life sector entities reported conducting approximately 2,000 reviews on insurance agents and educating about 5,500 insurance agents on the title protection framework
- entities identified approximately 500 instances of non-compliance with title protection requirements and reported about 200 remediation efforts to address uncredentialed title usage
- entities are continuing to work with agents who remain non-compliant to either bring them into compliance or, where necessary, initiate disciplinary measures
This initiative promotes consumer protection by ensuring individuals holding out as Financial Planners and/or Financial Advisors are appropriately credentialed and subject to oversight by the FSRA-approved credentialing bodies.
Strengthening credential holder oversight processes
In carrying out the 2025-2026 Supervision Plan, FSRA also conducted assessments at some of the credentialing bodies with the objective of strengthening credential holder oversight processes. Through this work, FSRA identified areas for improvement and additional opportunities to enhance credential holder oversight processes at the credentialing bodies.
Key areas for improvement include:
- strengthening oversight processes related to continuing education compliance, complaint handling, disciplinary disclosures, and environmental scanning
- improving the consistency and accuracy of information reported to FSRA, as this information appears on FSRA’s Check Credentials Tool
- enhancing escalation and follow-up practices to support effective and consistent oversight outcomes
FSRA will continue to monitor how credentialing bodies address the identified areas for improvement to promote high standards of business conduct and encourage continuous improvement in the sector.
FSRA’s 2025-2026 Supervision Approach
FSRA’s supervision plan for 2025-2026 intended to achieve the following outcomes:
- promote education and awareness about the framework among FSRA’s Life and Health Insurance sector
- assess how well the approved credentialing bodies are adapting as regulated entities under the Financial Professionals Title Protection Framework
- strengthen credential holder oversight among credentialing bodies to protect consumers
Life and Health Insurance sector initiatives
The objective of the supervision plan is to address uncredentialed title use by educating life insurers and MGAs in the Life and Health Insurance sector, building on the educational efforts initiated in 2024-2025. Strengthening awareness among these entities helps protect consumers by ensuring that individuals using protected titles meet the required education standards and are overseen by an approved credentialing body.
FSRA’s supervisory activities in the Life and Health Insurance sector include:
- following up with the MGAs and insurers initially engaged in fiscal 2024-2025 aiming to reduce uncredentialed title use
- engaging additional Life and Health insurance sector entities where FSRA has identified uncredentialed title usage to educate them about the Title Protection Framework
Strengthening Credential Holder Oversight Processes
FSRA’s 2025-2026 supervisory work also focused on strengthening credential holder processes at some of the credentialing bodies. Many of the areas for improvement identified during the 2024-2025 supervisory period were related to credential holder oversight processes, prompting FSRA to conduct assessments during the 2025-2026 fiscal year to enhance them. Strengthening these processes supports FSRA’s object of promoting high standards of business conduct and helps ensure credential holders are equipped to serve consumers.
Life and Health Insurance sector initiatives
FSRA continued to engage and provide education about the title protection framework and the implications of uncredentialed title usage to life sector entities. Building on the supervisory efforts initiated last year with seven (7) entities, FSRA expanded its scope this year to include two (2) additional life sector entities where instances of uncredentialed title usage were observed among insurance agents. These efforts help protect consumers by ensuring individuals using protected titles hold the required credentials and are subject to oversight by credentialing bodies.
Title Protection Results
During the 2025-2026 fiscal year, FSRA observed that the entities implemented the best practices shared last year, contributing to FSRA’s goal of reducing uncredentialed title usage among insurance agents. Below are the results reported by MGAs and insurers on their efforts to address uncredentialed title usage.
Monitoring title usage among insurance agents
All nine (9) life insurance entities are monitoring title usage among their insurance agents. For example, they review social media platforms to ensure compliance with the title protection rules. In addition, as part of routine advisor file reviews, they have incorporated a verification step using FSRA’s Check Credentials Tool to confirm appropriate title usage.
The nine (9) life entities reported that they have:
- conducted approximately 2,000 reviews of title usage
- identified around 500 insurance agents who were not compliant with title protection rules
- remediated roughly 200 insurance agents who had previously been non-compliant
The entities are continuing to work with agents who remain non-compliant to either bring them into compliance or, where necessary, initiate disciplinary measures.
Education efforts and outcomes
All nine (9) life insurance entities committed to educating their agents on the Title Protection Framework. This education helps agents understand title usage obligations under the Financial Professionals Title Protection Act, 2019 (FPTPA) and supports compliance with legislation. These efforts align with FSRA’s mandate to promote awareness and knowledge across FSRA’s regulated sectors.
The entities reported educating approximately 5,500 new and existing insurance agents on the provisions of the framework. For new agents, this education is incorporated into mandatory onboarding sessions, rules for appropriate title usage, and social media guidelines. For existing agents, compliance is reinforced through mandatory training programs focused on appropriate title usage.
Ensuring compliance with title protection requirements
Some entities reported taking steps to address non-compliance with title protection requirements. These measures included issuing warning letters to agents who use protected titles without the required credentials.
As part of its 2025-2026 Supervision Plan, FSRA is proactively educating life entities where uncredentialed title usage has been observed among insurance agents. However, compliance with title protection requirements is a shared responsibility across all sector participants and is essential to maintaining trust and supporting consumer protection. To support compliance and transparency, FSRA provides tools such as the Check Credentials Tool, which allows the public to verify whether an individual is appropriately credentialed to use a protected title. In addition, FSRA has established a clear and accessible complaints process for the public wishing to report instances of uncredentialed title usage.
Strengthening credential holder oversight processes
During the 2024-2025 supervisory period, FSRA conducted reviews of the approved credentialing bodies and issued recommendations to some of the credentialing bodies. In fiscal year 2025-2026, FSRA undertook follow-up supervisory work to assess how credentialing bodies responded to these recommendations and to evaluate progress made in strengthening credential holder oversight processes. The observations below reflect FSRA’s assessment of actions taken by credentialing bodies during the 2025-2026 fiscal year in response to recommendations issued in 2024-2025.
- Improve the oversight of credential holder continuing education (CE) compliance processes. In 2025-2026, FSRA observed that the credentialing body that received this recommendation strengthened its CE compliance process by contacting credential holders who did not complete their CE requirements. If non-compliance persisted, the credentialing body updated the status of credential holders on FSRA’s Check Credentials Tool to reflect that they had failed to meet CE obligations.
- Ensure that disciplinary decisions imposed on credential holders are promptly published on the credentialing body’s website. In 2025-2026, FSRA observed that the credentialing body that received this recommendation promptly disclosed disciplinary actions taken against credential holders on its public website.
- Ensure that credentialing educational curricula are reviewed according to the credentialing body’s curriculum review policies. In 2025-2026, FSRA observed that the credentialing body that received this recommendation was in alignment with its curriculum review procedures.
- Ensure the accuracy of information reported to FSRA on the credentialing body’s Annual Information Return (AIR). In 2025-2026, the credentialing body that received this recommendation committed to submitting accurate data in future AIR filings.
- Ensure adherence to the credentialing body’s defined service standards throughout the complaint handling process. In 2025-2026, FSRA observed that the credentialing body that received this recommendation took steps to strengthen its complaint handling process and adhere to its defined service standards for complaint handling. FSRA will continue working with the credentialing body to address this recommendation.
Overall, FSRA observed progress in several areas where recommendations were issued in prior supervisory periods, demonstrating increased alignment with oversight expectations. Where remediation efforts remain in progress, FSRA will continue to monitor implementation to ensure sustained improvements in credential holder oversight processes at the credentialing bodies.
FSRA’s expectations for credential holder oversight functions
To support effective oversight of credential holders and promote high standards of business conduct, FSRA’s supervisory work also focused on credential holder oversight functions that credentialing bodies are expected to maintain. These functions play a critical role in protecting consumers by ensuring that credential holders remain competent, accountable, and subject to effective oversight.
The sections that follow outline FSRA’s observations and expectations related to key oversight functions, including environmental scanning, complaint handling, disciplinary process, CE compliance, and transmitting credential holder information for FSRA’s Check Credentials Tool.
Environmental scanning: Monitoring external disciplinary actions
An effective environmental scanning process enables credentialing bodies to monitor external sources for disciplinary or enforcement actions involving their credential holders. It allows them to assess whether those individuals remain qualified to hold the credential. Where concerns are identified, the process ensures credentialing bodies can take timely action to uphold professional standards and protect consumers.
Review observations
FSRA’s review highlighted opportunities to enhance the effectiveness of credentialing bodies’ environmental scanning processes and related follow-up actions. FSRA found the following:
- A credentialing body did not perform routine environmental scans. FSRA required the credentialing body to comply with its policy to perform environmental scans to routinely identify any disciplinary or enforcement actions taken against its credential holders.
- A credentialing body did not have an efficient process to investigate any possible matches flagged during its environmental scans. FSRA required the credentialing body to implement a procedure to investigate any possible matches flagged during its environmental scans. A possible match refers to a case where external enforcement, or disciplinary actions appear to involve one of the credentialing body’s credential holders.
- An opportunity for credentialing bodies to strengthen the actions taken when a possible match is identified during the environmental scanning process. FSRA recommended that credentialing bodies contact the credential holder to confirm whether the disciplinary or enforcement action pertains to them and, if confirmed, initiate a review for misconduct and/or breaches of the credentialing body’s code of conduct. If the credential holder does not respond after reasonable attempts to contact them, FSRA identified an opportunity for the credentialing bodies to establish a procedure to address situations where a credential holder remains unresponsive.
FSRA’s expectations
FSRA expects credentialing bodies to demonstrate the following key components of an effective environmental scanning process that achieves the intended outcomes described above:
- Routine monitoring of disciplinary and enforcement information
Credentialing bodies must regularly monitor publicly available information, such as websites of other credentialing bodies, regulators, and other relevant platforms or databases, to identify disciplinary and/or enforcement actions that may affect credential holder suitability. - Timely review and investigation of possible matches
When environmental scans flag a possible match to a credential holder, credentialing bodies must promptly verify whether the action pertains to a credential holder. This includes assessing relevant facts, documenting the rationale for decisions, and initiating further review where necessary. - Defined escalation pathways for confirmed matches
Credentialing bodies should have clear procedures to escalate confirmed matches to the appropriate internal teams for investigation, including reviews for potential misconduct or breaches of the code of conduct. - Documentation and record-keeping
Credentialing bodies should maintain documentation of all findings, decisions, and actions taken during environmental scans to ensure accountability. - Clear approach for non-responsive credential holders
Credentialing bodies would benefit from establishing steps to address situations where credential holders fail to respond to inquiries arising from environmental scan findings.
Complaint handling process
An effective complaints handling process enables credentialing bodies to respond to allegations of credential holder misconduct promptly and consistently. It provides the public with a channel to raise concerns when professional standards are not met, reinforcing accountability and high standards of conduct within the sector. An effective process strengthens consumer protection and fosters trust in individuals who use the protected titles. In addition, complaints information may provide valuable insights into credential holders’ conduct and may help inform a credentialing body’s approach to continuing education and disciplinary processes.
Review observations
FSRA’s complaints handling process review identified areas for improvement for some credentialing bodies. FSRA found the following:
- A credentialing body previously did not meet its complaint handling service standards and has not yet demonstrated that recent process changes are resulting in timely file progression. FSRA required the credentialing body to meet its defined service standards and ensure complaint files are actively managed toward resolution.
- An opportunity for a credentialing body to enhance the accessibility of its complaint handling process. FSRA provided recommendations aimed at improving ease of navigation and aligning the credentialing body’s public facing complaints webpage with accessibility best practices.
FSRA’s expectations
FSRA expects credentialing bodies to demonstrate the following key components of an effective complaint handling process that achieves the intended outcomes described above:
- Clear and defined service standards
Credentialing bodies must establish timelines and assign responsibilities to ensure complaints are addressed promptly and handled consistently. - Procedures to ensure timely and effective complaint resolution
Credentialing bodies must implement clear steps to prioritize, review, and resolve complaints, and communicate the outcome of each complaint. - Accessible complaint submission process
Credentialing bodies must provide a documented, publicly accessible complaints process. The credentialing body’s webpage should include the following features:- a prominently displayed link on the credentialing body’s homepage that directs users to the dedicated complaints webpage
- an online submission form for direct complaint filing
- contact details for inquiries about the complaints process
- an explanation of how complaints are handled
- information on the types of complaints within the credentialing body’s jurisdiction
- Detailed and consistent record-keeping
Credentialing bodies should maintain consistent documentation of complaint-related actions and decisions to support accountability.
Credential holder disciplinary process
An effective disciplinary process ensures that credential holder misconduct is addressed in a fair, transparent, and consistent manner. This process ensures that cases of credential holder misconduct are consistently reviewed in accordance with the credentialing body’s established disciplinary procedures. It protects consumers by disclosing when disciplinary action has been imposed against a credential holder, enabling the public to make informed decisions when dealing with individuals who use the protected titles.
Review observations
FSRA identified instances where disciplinary actions imposed on credential holders were not promptly or accurately reported on a credentialing body’s disciplinary webpage. FSRA issued a recommendation requiring the credentialing body to promptly update its disciplinary webpage following the imposition of any disciplinary action.
FSRA’s expectations
FSRA expects credentialing bodies to demonstrate the following key components of an effective disciplinary process that achieves the intended outcomes described above:
- Accessible and timely public disclosure of disciplinary information
Credentialing bodies must provide disciplinary information about their credential holders transparently and make it publicly accessible on their website. - Detailed and consistent record-keeping
Credentialing bodies should maintain documentation of all disciplinary actions and decisions to support accountability.
Credential holder Continuing Education (CE) compliance
An effective CE compliance process enables credentialing bodies to ensure that credential holders meet ongoing CE requirements, which ensures credential holders maintain high standards of competence and supports consumer protection. It helps identify individuals who are not compliant and ensures appropriate steps are taken to address non-compliance. Where compliance is not achieved, the process ensures that credential holder statuses are promptly and accurately updated on FSRA’s Check Credentials Tool, allowing consumers to make informed decisions and promoting professional conduct within the sector.
Review observations
FSRA advised a credentialing body to strengthen its approach for contacting CE non-compliant credential holders to ensure they are addressed in a timely and consistent manner. FSRA also recommended that the credentialing body accurately reflect the status of CE non-compliant credential holders on FSRA’s Check Credentials Tool. Additionally, FSRA identified an opportunity for the credentialing body to enhance its CE compliance process by using appropriate verification methods to confirm that credential holders have met their CE requirements.
FSRA’s expectations
FSRA expects credentialing bodies to demonstrate the following key components of an effective CE compliance process that achieves the intended outcomes described above:
- Process to review and confirm adherence to CE requirements
Credentialing bodies must have a process to monitor credential holders’ completion of CE requirements - Timely identification and resolution of CE non-compliance
Credentialing bodies should promptly address CE non-compliant credential holders to ensure issues are resolved and credential holder statuses remain accurate. - Verification of CE compliance
Credentialing bodies should review supporting documentation provided by credential holders to confirm compliance with CE requirements. - Proportionate CE compliance audit sample size
Credentialing bodies should ensure that the size of their CE compliance audit sample is proportionate to the total number of credential holders they oversee.
Credential holder information for FSRA’s Check Credentials Tool
FSRA requires credentialing bodies to provide accurate and timely information on both current and former credential holders for inclusion in FSRA’s Check Credentials Tool. This requirement ensures consumers have access to complete and reliable information in order to make informed decisions about the financial professionals they choose to work with.
Review observations
FSRA is engaging with a credentialing body to remediate an inconsistency with reporting requirements relating to the display of former credential holders on the Check Credentials Tool.
FSRA’s expectations
FSRA expects credentialing bodies to demonstrate the following components to ensure accurate, timely, and transparent reporting of credential holder information for FSRA’s Check Credentials Tool:
- Clear identification of credential holder status
Credentialing bodies must have a process to monitor credential holders’ completion of CE requirements - Timely identification and resolution of CE non-compliance
Where a credential holder’s status changes, updates must be reflected promptly to support transparency and informed consumer decision-making.
Conclusion
FSRA’s 2025-2026 supervisory work highlights continued progress in promoting appropriate use of protected titles and strengthening credential holder oversight practices across the sector.
FSRA encourages credentialing bodies and sector participants to build on these efforts, address identified opportunities and maintain effective practices that promote accountability and consumer confidence.
FSRA will continue to engage with the sector and monitor progress in support of high standards of business conduct and consumer protection.