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On December 18, 2025, the Government of British Columbia introduced the long-awaited restricted licensing framework ("Framework") for businesses that sell insurance products incidental to their primary business activities, such as add-on insurance offered in connection with the sale of vehicles or electronics. The Framework is intended to address the perceived regulatory gap between full insurance licensing and the lack of oversight for incidental sales of insurance, and is broadly consistent with restricted licensing regimes in Alberta, Saskatchewan, Manitoba, and New Brunswick.
Under the Restricted Insurance Agent License Regulation ("Regulation"), certain businesses that were previously exempt from licensing under the Insurance Licensing Exemptions Regulation will be required to obtain a Restricted Insurance Agency ("RIA") License to sell specified insurance products. An RIA Licence allows certain businesses to sell specific types of insurance through its employees or contractors, who will not need to hold their own individual licences.
Businesses Required to Hold an RIA Licence
The following businesses will need to hold an RIA Licence in order for their employees or contractors to sell the corresponding class of insurance products:
| Type of Business ("class of persons") | Classes of Insurance |
| Construction equipment dealerships |
Credit protection insurance Construction equipment warranty insurance Guaranteed asset protection insurance |
| Credit grantors | Credit protection insurance |
| Customs brokers | Cargo insurance |
| Deposit-taking institutions | Credit protection insurance |
| Extraprovincial trust corporations | Credit protection insurance |
| Farm implement dealerships |
Credit protection insurance Farm implement warranty insurance Guaranteed asset protection insurance |
| Freight-forwarding companies | Cargo insurance |
| Funeral providers | Funeral services insurance |
| Mortgage brokerages | Credit protection insurance |
| Motor vehicle dealers | Credit
protection insurance Guaranteed asset protection insurance Vehicle warranty insurance |
| Peer-to-peer vehicle service providers | Rented vehicle insurance |
| Pleasure craft dealerships | Credit
protection insurance Guaranteed asset protection insurance Pleasure craft warranty insurance |
| Portable electronic vendors | Portable electronics insurance |
| Transportation companies | Cargo
insurance Travel insurance |
| Travel agents | Rented vehicle
insurance Travel insurance |
| Travel wholesalers | Rented vehicle
insurance Travel insurance |
| Trust companies | Credit protection insurance |
| Vehicle rental agencies | Rented vehicle insurance |
Administration and Oversight
The Insurance Council of British Columbia (the "Council") will administer the RIA licensing regime and establish rules governing licence-holder obligations. These rules are intended to promote the transparent and responsible sale of incidental insurance and to enhance consumer protection. The Council is expected to release further details regarding the proposed licensing program in January 2026.
Coming Into Force and Transition Period
The Regulation will come into force on January 1, 2027, with a three-month transition period ending on March 31, 2027. The Council expects to begin accepting applications for RIA Licences in November 2026.
As of January 1, 2027, businesses identified in the Regulation that wish to begin offering the permitted types of insurance must hold an RIA Licence. Businesses that have previously sold insurance incidentally pursuant to licensing exemptions and who fall within the scope of the Regulation must submit an application for an RIA Licence by March 31, 2027 in order to continue selling the permitted classes of insurance.
Key Takeaways
The Regulation establishes a formal RIA licensing regime for certain businesses that sell insurance incidentally to their primary business activities, expanding regulatory oversight and enhancing training, transparency, and consumer protection requirements. Businesses currently relying on licensing exemptions should review the insurance products they offer, assess whether they are required to obtain an RIA Licence under the Regulation, and monitor developments from the Council to prepare for compliance. Failure to obtain the required Licence by the applicable deadline may result in non-compliance with the Financial Institutions Act and the loss of authority to offer insurance products.
The foregoing provides only an overview and does not constitute legal advice. Readers are cautioned against making any decisions based on this material alone. Rather, specific legal advice should be obtained.
© McMillan LLP 2025
