British Columbia’s New Restricted Insurance Agent Licensing Regime

Changes to Legislation and New Licensing Required for the Incidental Sale of Insurance

In December 2025, the BC government enacted amendments to the Financial Institutions Act, RSBC 1996, c 141 (the “Act”) and a new Restricted Insurance Agent Licence Regulation  (the “RIA Regulation”), which creates a licensing framework for certain businesses that sell insurance incidentally to their ordinary goods or services.

The amendments to the Act include the addition of a new section 174.1 that authorizes the issuance of a restricted insurance agent (“RIA”) licence to a prescribed list of persons who carry on a prescribed class of insurance business. The amendments to the Act and the RIA Regulation come into force effective January 1, 2027. Businesses currently selling insurance under the Insurance Exemption Regulation, B.C. Reg. 366/2007 (the “Exemption Regulation”), must apply for an RIA licence by March 31, 2027 to continue those sales.

The changes to the legislation and resulting licensing regime are intended to protect BC consumers. The RIA Regulation replaces several existing licensing exemptions and the restricted travel insurance framework with a formal RIA licence for prescribed non-insurance businesses.

Affected Businesses and Classes of Insurance

The RIA Regulation prescribes 18 classes of business that are subject to the RIA licensing requirements and, in table form, the classes of insurance each prescribed class of business may sell. Please see below for a copy of the table set out in section 4 of the RIA Regulation.

Once a prescribed business is licensed, the business, acting through its employees and agents in BC, may conduct insurance activities only for the classes of insurance specified in its licence. Individual representatives do not need separate insurance licences, but they must act through the licensed business and complete the required training.

BC and Other Provinces with Restricted Insurance Agent Licensing Regimes

BC joins Alberta, Saskatchewan, Manitoba and New Brunswick in regulating incidental insurance sales through restricted licensing regimes. However, the approaches differ, particularly on training and oversight. Alberta’s restricted licence categories have no prescribed education or experience requirements, while Saskatchewan, Manitoba and New Brunswick generally leave it to the restricted agent or sponsoring insurer to ensure representatives are properly trained. BC, on the other hand, is more prescriptive: representative training must be product-specific and accredited by the Insurance Council of British Columbia (the “Insurance Council”), accreditation is time-limited and must be renewed, and the designated representative must complete a separate Insurance Council course. Insurers and businesses with national programs should adapt their existing approach for BC, as a licence in one province does not authorize the same activity in another.

Regulatory and Licensing Requirements

Insurance products prescribed in the RIA Regulation must be optional and offered only incidentally to the licensee’s ordinary business. Prescribed businesses must comply with the following:

• appoint a designated representative approved by the Insurance Council, who must be a sole proprietor, partner, director or officer of the business and must complete the Insurance Council’s designated representative course;
• have written authorization from at least one insurer authorized in BC to write the relevant prescribed class of insurance, subject to a limited exception for certain manufacturer or retailer guaranteed warranties;
• hold errors and omissions coverage of at least $1 million per claim and $2 million in the annual aggregate, and provide suitability information on their structure, ownership, management and legal, financial, licensing and disciplinary history; and
• all selling representatives must complete accredited training before offering any of the prescribed insurance products, and consumers must receive required written disclosures, including that the insurance is optional and any cancellation rights.

Here is a link to the Insurance Council’s website and information about the designated representative course.  Here is a link to the Insurance Council’s page on training requirements for RIA representatives.

Term Licensing Where Accredited Training Is Not Yet Available

Recognizing that accredited training may not be available for every product at launch, the Insurance Council has advised (including in its November 3, 2026 webinar) that it may issue a short-term RIA licence to an applicant that:

• applies before March 31, 2027;
• otherwise meets the licensing requirements; and
• confirms that its representatives have completed an existing, non-accredited training program covering the RIA performance requirements.

The Insurance Council is clear that this is not a waiver of training; it allows time for the existing program to be accredited. A term licence expires no later than May 31, 2028 and may be converted to a standard licence once accredited-training conditions are met.

Key Implementation Dates

The March 31, 2027 deadline does not necessarily end every existing exemption immediately. Under section 7 of the RIA Regulation, a qualifying exemption continues for a timely applicant until 30 days after the Insurance Council refuses the application or 90 days after it issues the licence. Separate transition rules apply to travel agents, travel wholesalers and existing restricted travel insurance licensees.

Insurers’ Responsibilities

Insurers underwriting affected products will play a key role in compliant distribution. They should identify distribution relationships with prescribed businesses, assess oversight, monitoring and record-keeping processes, and help coordinate the development and accreditation of product training. Not every agreement will require amendment, but contracts and procedures should be reviewed to confirm that responsibilities for licensing, training, disclosures, supervision and compliance are appropriately allocated.

Next Steps Prior to the Effective Date

In preparation for the January 1, 2027 effective date, affected businesses and insurers should review their insurance products against the prescribed classes of business and insurance and identify current arrangements that rely on licensing exemptions or restricted travel insurance licences. Businesses should also identify an individual to act as a designated representative, assess existing representative training, confirm insurer authorization and errors and omissions coverage, and update distribution contracts, consumer disclosures and compliance procedures to comply with the RIA Regulation.

Starting early will reduce the risk of interruptions to insurance distribution once the new regime takes effect.

Please contact us directly if you have any questions.