On July 3, the Ontario Ministry of Finance (MOF) published a new proposal introducing amendments in response to stakeholder concerns about life and health (L&H) managing general agency (MGA) oversight already introduced into that province’s Insurance Act.

The changes to the Act occurred in 2024 to create a dedicated new licensing framework for L&H MGAs. They established a definition of what a L&H MGA is for licensing purposes, set out the minimum requirements for obtaining the new license and provided the Financial Services Regulatory Authority (FSRA) with rulemaking authority.

Although the MOF and FSRA have since taken steps to implement the new framework, their efforts were met with resistance from stakeholders who raised concerns about the application of the new licensing requirements and the scope of persons and entities captured under the changes for licensing purposes. The MOF announced suddenly in February this year that the June 1 implementation date would be delayed.

“In light of these concerns, in the 2026 Ontario Budget, the government announced a pause on the implementation of the licensing framework so that this feedback could be further considered. At this time, the MOF is consulting on proposed amendments that aim to respond to stakeholder concerns,” the proposal summary states. “The primary objective of these amendments is to further narrow the scope of entities potentially captured as L&H MGAs for licensing purposes.”

Stakeholders have until August 17 to respond.

“Currently, section 407.2 (of the Insurance Act) prescribes a long list of regulated activities and a broad range of agreements that may lead a person or entity to be captured for L&H MGA licensing. In practice, many persons or entities that were not intended to require an L&H MGA license would potentially be captured, including ones that are already duly licensed by FSRA for the activities they perform,” the notice states. The proposal also notes that education providers, for example, were similarly captured by the previous definition even though they “would not reasonably be considered L&H MGAs.”

The proposal also discusses accountability for sub-managing general agents and new exemptions, including for insurers and for L&H MGAs that solely facilitate the distribution of group insurance.

“FSRA’s past supervisory reviews involving the L&H MGA distribution channel focused on L&H MGAs distributing individual insurance products to retail consumers. At this time the MOF believes there is less evidence that L&H MGAs solely facilitating the distribution of group insurance contracts while performing the prescribed agent-related activities, pose the same risks to consumer protection,” the ministry states.