As discussed in previous blog posts (see here and here), the Ontario Employment Standards Act, 2000 (ESA) was amended to include new licensing requirements for recruiters and temporary help ‎agencies (THAs).

The new regime requires that recruiters and THA's operating in Ontario obtain a licence or risk facing penalties. Recently, the province announced that the date by which temporary help agencies must have a licence to operate and recruiters must have a licence to act as a recruiter has changed from January 1, 2024 to July 1, 2024. This provides THAs and recruiters an additional six (6) months to submit an application for a licence.

The government delayed the new licensing rules after industry stakeholders expressed concern that the requirements were too burdensome for small recruiting firms.

In a letter to recruiters, the honourable David Piccini (Minister of Labour, Immigration, Training and Skills Development) confirmed that he instructed the province to take the time over this six-month extension to consider further changes to the licensing framework, including narrowing the scope of who needs to provide a letter of credit, as well as potentially accepting alternate forms of security.1 As things currently stand, when applying for a new licence, an applicant must provide an electronic irrevocable letter of credit in the amount of $25,000.

The province began accepting applications for a licence in July 2023 and has indicated that applications that have already been submitted remain valid.


1. Chris Hannay, "Ontario delays new regulations on recruitment agencies after industry outcry", The Globe & Mail (11 November 2023).

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