We know that there has been a lot of concern and confusion among our members regarding temporary help agency (THA) and recruiter licensing, particularly with respect to the requirements for licensure and the letter of credit. On April 29, 2024, the Ontario government amended the regulations that are expected to take effect on July 1, 2024. 

Who do the licensing requirements apply to?

The licensing requirements apply to THAs and recruiters.  

A temporary help agency is an employer that employs people for the purpose of assigning them to perform work on a temporary basis for clients of the employer. 

A recruiter is a person (which includes a corporation, partnership, or individual/sole proprietorship) who, for a fee, finds or attempts to find:  

  • employment in Ontario for prospective employees, excluding an employee who does so as a duty of the employee’s position; or 
  • employees for prospective employers, excluding an employer who finds or attempts to find employees to be employed by that employer; and  
  • an employee who finds or attempts to find employees for prospective employers as a duty of the employee’s position.  

There are a number of entities that are excluded from the definition of “recruiter,” such as certain educational institutions, trade unions, registered charities, and others (detailed information on the exclusions is available in the regulation). 

What is the effect of the recently announced amendments?

  • A recruiter is no longer required to provide security if the recruiter is not recruiting foreign nationals or if the recruiter, even if recruiting foreign nationals, only recruits for positions with wages at or above the median hourly wage for the province as published on a Government of Canada website
  • Where a single organization applies both for a THA licence and a recruiter licence, it will not be required to pay duplicate fees or provide duplicate security. 
  • Security may now be provided in either one of two forms: an electronic irrevocable letter of credit or a bond of an insurer licensed under the Insurance Act to write surety and fidelity insurance. 

“Foreign national” means an individual who is not a Canadian citizen or a permanent resident within the meaning of the Immigration and Refugee Protection Act.

The licence application and annual renewal fee is $750. Subject to certain details, if the same legal entity applies for both a THA licence and a recruiter licence, it generally does not have to pay the licence fee twice each year.  


The recruiter can make changes during the term of the licence. If there is a term and condition of a licence (e.g., not hiring foreign nationals), but the licensee no longer wants the term and condition to apply, the licensee must provide security that meets specific requirements.  

If the licensee has already provided security and there are no terms and conditions of the licence, but the licensee wants a term and condition to apply, the licensee must provide certain written notice.  

Recruiters must pay attention to the effective date of requested changes. 


Government of Ontario – Licensing for temporary help agencies and recruiters 

O. Reg. 182/24: Licensing – Temporary Help Agencies and Rrecruiters (ontario.ca) 

Hicks Morley – Important Amendments Made to the Temporary Help Agency and Recruiter Licensing Framework in Ontario