Canadian regulators just rewrote the playbook on how insurers and OmbudServices work together - the first overhaul in more than a decade.
On April 29, 2026, the Canadian Council of Insurance Regulators published its updated Insurance OmbudServices Cooperation and Oversight Framework. The original version had sat unchanged since CCIR approved it in June 2015. The revision came after over 18 months of collaboration between CCIR, the OmbudService for Life & Health Insurance (OLHI), the General Insurance OmbudService (GIO), the Canadian Life and Health Insurance Association (CLHIA), and the Insurance Bureau of Canada (IBC).
The Framework spells out how Canada's two insurance-sector OmbudServices and CCIR cooperate to keep the consumer dispute resolution system running effectively across the Canadian Insurance Market. It sits alongside each OmbudService's Terms of Reference and by-laws, as well as CCIR's Conduct of Insurance Business and Fair Treatment of Customers Guidance.
Seven principles form the backbone of the document, all drawn from global dispute resolution standards - Independence, Accessibility, Scope of Services, Fairness, Methods and Remedies, Accountability and Transparency, and Independent Evaluation.
On the Independence front, each OmbudService should have a board where a majority of directors are independent. The Board Chair should be an independent director, elected or appointed on the recommendation of a nominating committee consisting solely of independent directors. Budgets and mandatory assessments for Participating Companies - regulated insurance companies required by law to join an OmbudService - should be approved by a board committee composed solely of independent directors.
Accessibility means every OmbudService should deliver its services at no cost to consumers, fully funded by Participating Companies. Those services should be available in both English and French and reachable through toll-free telephone, regular mail, fax lines, and a website or other digital platforms.
The Scope of Services principle carries an interesting wrinkle on jurisdiction. Where doubt exists about whether a complaint falls within an OmbudService's Terms of Reference, that doubt should be resolved in favour of dealing with the complaint rather than rejecting it. OmbudServices should also have processes in place for identifying and handling Systemic Issues, and the Chair of CCIR's OmbudService Oversight Standing Committee (OOSC) should receive timely notification when one is identified.
On Fairness, each OmbudService should publish a Fairness Standard approved by its Board of Directors. The Framework makes clear that dispute resolution through an OmbudService is not meant to provide a parallel court system - the goal is a dispute resolution process that encourages fair business dealings for consumers.
When it comes to Methods and Remedies, OmbudServices can use conciliation, mediation, investigation, or non-binding adjudication, and may employ a variety of methods in attempting to resolve the same dispute. Written recommendations may include a non-binding recommendation for financial restitution for direct loss, or a non-binding recommendation that a Participating Company take a particular course of action to resolve the matter, which may include compensation for non-financial loss. If a Participating Company does not follow a formal recommendation or does not cooperate with an inquiry or investigation within a reasonable time, the OmbudService should publicly disclose that the Participating Company has failed to comply or cooperate - while preserving the confidentiality of the consumer.
The engagement schedule tightens considerably under the new Framework. CCIR shall meet with each OmbudService's executive management a minimum of two times per year and with the Board of Directors at least once per year. Each OmbudService shall provide CCIR quarterly reports on complaint volumes and the nature of complaints received. Twice a year, each OmbudService shall engage in dialogue with CCIR regarding identified Trends, emerging Trends under monitoring, and any reported Systemic Issues.
The OOSC shall publish an annual report highlighting its major activities - a public record of CCIR's understanding of the work of the OmbudServices, including the extent to which CCIR believes the OmbudServices are adhering to the principles and associated implementation guidelines in the Framework and are committed to continuous improvement of Canada's Insurance Market complaint resolution system.
Patrick Déry, Chair of CCIR and Superintendent, Financial Institutions at the Autorité des marchés financiers, said the OmbudServices are a crucial component of a well-functioning consumer protection policy framework, adding that CCIR Members are committed to ensuring insurance customers are treated fairly and that includes access to an effective consumer dispute resolution service.
Erica Hiemstra, Vice Chair of CCIR, Chair of the OmbudServices Oversight Standing Committee and Head, Insurance Conduct, Property and Casualty Insurance at the Financial Services Regulatory Authority of Ontario, said the updated Framework enhances accountability, engagement and information sharing between insurance regulators and the OmbudServices, and that these changes will help ensure that the public interest goals of the Framework are consistently achieved.
Each OmbudService should also undergo an independent evaluation at least every five years. The independent evaluator should have access to all relevant materials and personnel, including the Board of Directors and its minutes. CCIR should be interviewed as part of the evaluation and may suggest areas of focus that are important to CCIR. The evaluator's report, along with any response by the OmbudService, should be published as soon as practicable.
A few definitions worth noting: a Participating Company is a regulated insurance company, sometimes referred to as a Subscriber or a Member Company, required by law to become a member of an OmbudService offering independent dispute resolution services. Independence means the absence of unwarranted influence from the affected insurance sector, or Participating Companies within it, which would cause a reasonable person to question whether any person engaged by an OmbudService to deal with consumer complaints can fairly and effectively resolve complaints. A Trend refers to a pattern of increasing or decreasing frequency or severity of specific types of complaints. Systemic Issue and Standards carry meanings set out in each OmbudService's Terms of Reference.
The updated Framework took effect in April 2026 and applies across the Canadian Insurance Market. The full text of the Insurance OmbudServices Cooperation and Oversight Framework is available at https://www.ccir-ccrra.org/Documents/View/4036.
