BrokerExamSometimes, and only with an exemption granted before the second job starts. The rule is in O. Reg. 991, s. 5 (1) (b). An individual qualifies for registration only where “the individual’s only business or employment is that of,”
(i) an insurance broker, or
(ii) an insurance broker and life insurance agent, and
(iii) such other business as the Qualification and Registration Committee considers appropriate when carried on in accordance with such terms as the Committee stipulates;
By-Law No. 3, s. 3.2 (b), repeats the same three-part rule for every individual licensee, so it applies at Level 1 and at every level above it.
How RIBO reads it
RIBO Guidance 005, published on February 6, 2026, is how the Registered Insurance Brokers of Ontario (RIBO) runs the third branch. It reads the section plainly: “any other employment or business that is not of an insurance broker or a life agent requires an exemption from the QR Committee.” The purpose it gives is to prevent “real or perceived opportunities for coercion and conflict of interest with respect to insurance consumers.”
The request goes to the Qualification and Registration (QR) Committee as a letter and a secondary business exemption form, with a supporting letter from the Principal Broker. It is made before the second occupation begins, “whether you are newly licensed or have been a licensee for several decades”. For someone who has just passed the exam, one line matters most: “New licence applications will be accepted only after the exemption request has been granted.” The licence application itself, and the Secondary Business Exemption Form it may need, are covered in Passed RIBO Level 1: the steps to your licence.
How the lists work
RIBO-005 sorts occupations into four kinds of result.
- Approved. An occupation on the approved list is granted an exemption automatically once the paperwork is in, provided it “falls within the parameters set by the QR Committee”. One outside those parameters goes to the Committee for review.
- Approved with conditions. A separate list of licensed professions is approved subject to a condition. For most, the condition is an attestation that the other regulator has been told about the RIBO licence or application.
- QR review required. The Committee looks at each request “on the individual merits and facts of each individual request”, and the guidance says a decision on one case is not binding on a similar one later. RIBO prints this group with the incompatible occupations: its List A is headed “Incompatible Occupations List” and introduced as examples of occupations “that require QR Committee approval”.
- Not allowed. Certain occupations “have been deemed to be an unmanageable conflict of interest”, and applications for them “will be refused”.
Even the last kind is not a closed door. The guidance says so in its overview:
Please note, even in cases where the occupation is deemed “incompatible” with the insurance broker profession, licensees may still submit an application for consideration by the Committee.
A request in the review or not-allowed groups also needs further letters from the individual and the Principal Broker on how both will manage undue influence and conflicts of interest.
The occupations candidates ask about
Each of these is stated as RIBO-005 marked it on September 30, 2026.
- Life and accident and sickness agent. Approved. The finance list names “Financial Services Regulatory Authority of Ontario (Life and A&S Agents)”.
- General insurance agent (OTL licence) or adjuster. Not allowed. The licensed occupations list marks FSRA “General Insurance Agents (OTL Licence)” and “Adjusters” as “Not Allowed”. The same boundary between licences is covered in RIBO or LLQP: which licence do you need?
- Mortgage agent or mortgage broker. Not allowed. FSRA “Mortgage Agents” and “Mortgage Brokers” are each marked “Not Allowed”.
- Real estate. Not allowed. The Real Estate Council of Ontario line reads “Not Allowed”.
- Car sales. Not allowed as a licensed occupation. The Ontario Motor Vehicle Industry Council line reads “Not Allowed”, and “Employees and Owners of Dealerships and Mechanics” appear on List A, which RIBO-005 heads “Incompatible Occupations List” and introduces as occupations “that require QR Committee approval”.
- Paralegal or lawyer. Approved with a limit. The Law Society of Ontario line reads: “Restricted to providing legal advice to the insurance brokerage you are licensed under only, any outside employment would be considered incompatible and prohibited. (Undertaking required.)”
- Bank employee. On List A, which RIBO-005 heads “Incompatible Occupations List” and introduces as examples of occupations “that require QR Committee approval”, with loan and trust company employees.
The guidance lists many more, from rideshare drivers and servers to Red Seal trades and the regulated health professions, and it gives both the approved list and List A as examples, not complete lists. Check RIBO-005 itself for the full lists before relying on one line of it.
After the exemption
A change of employment later needs the support of the Principal Broker of the hiring brokerage. Under By-Law No. 3, s. 2.7 (a) (ix), a licensee notifies RIBO’s CEO within ten calendar days of any new or changed secondary employment outside broking, if one is approved under s. 3.2 (b).
The code of conduct still applies, and RIBO-005 points to two paragraphs of O. Reg. 991, s. 14. Under paragraph 7, a member who engages in another business or occupation concurrently “shall not allow such outside interest to jeopardize the member’s integrity, independence or competence.” Under paragraph 7.1, a member “shall disclose in writing to a client or prospective client any conflict of interest or potential conflict of interest of the member that is associated with a transaction or recommendation.”