From the start of 2026, an engineer licensed in one Canadian province who wanted to work in Ontario could submit registration documents to the receiving regulator and, within 10 business days, receive deemed certification to begin practising.
No additional training. No supplementary examinations. No months-long wait while files moved through committee review. Just acknowledgment of credentials earned elsewhere in Canada and permission to start work while full registration processed over the following six months.
This is not a pilot or a discretionary policy. It is law. Ontario’s “As of Right” framework, affecting more than 50 regulatory authorities and 300 professional certifications, went live at the start of the year.
On the same day, the federal Free Trade and Labour Mobility in Canada Act came into force, mandating interprovincial regulatory harmonisation across the country. Together, these measures represent one of the most ambitious attempts at regulatory coordination in Canadian history – an effort to solve what officials have long called the country’s “mini-EU” problem without creating a single national regulator to do it.
The experiment tests a specific proposition: whether binding timelines and financial penalties can produce the coordination that voluntary frameworks have failed to achieve.
The question now is whether the infrastructure exists to make it work.
The coordination challenge Canada faces
Canada has 13 provincial and territorial regulatory systems, each with dozens of independent professional regulators. An accountant certified by CPA Alberta cannot automatically practise in British Columbia. A teacher licensed in Nova Scotia faces barriers in Saskatchewan.
Even within provinces, regulatory authorities operate autonomously, with their own standards, timelines, and digital systems – or lack thereof.
A 2025 survey by BDO found that while 88 per cent of Canadian businesses engage in interprovincial trade, 58 per cent said regulatory barriers prevented expansion into additional provinces.
Though 88 per cent of Canadian businesses engage in interprovincial trade, 58 per cent say regulatory barriers prevented expansion into additional provinces.
For workers, the barriers are more personal. Immigrants to Canada routinely cite the inability to transfer credentials across provincial lines as a reason qualified professionals end up in jobs below their skill level.
Previous efforts at reform have relied on voluntary cooperation. The Canadian Free Trade Agreement (CFTA), which predates the new legislation, established principles for labour mobility and created provincial Labour Mobility Coordinators to support credential recognition.
But without binding timelines or enforcement mechanisms, progress has been uneven. The result was a patchwork that depended more on institutional culture than on legal obligation.
Ontario’s approach changes that calculus through enforcement rather than persuasion.
The federal act provides legal backing for interprovincial recognition, but it lacks the penalty structure that gives Ontario’s regulations teeth. In practice, Ontario is doing the heavy lifting – the federal framework legitimises the policy direction, but provincial penalties drive compliance.
How deemed certification works in practice
The mechanics are straightforward. An individual certified in another Canadian province or territory submits registration documents to an Ontario regulatory authority. Within 10 business days, the regulator must send an acknowledgment notice.
Upon receipt, the applicant is deemed certified and can begin work immediately. That certification lasts up to six months, during which the authority completes any remaining steps for full registration.
There are conditions. Applicants must attest that they are in good standing in their home jurisdiction, have not been refused certification by another regulator in the past two years, and are not subject to ongoing professional misconduct or incompetence proceedings. If any of that information proves inaccurate, the deemed certification can be revoked.
The restrictions on regulators are more significant. Authorities cannot require additional material training, experience, examinations, or assessments except in limited circumstances. Application fees are capped at standard certification levels. If an examination is required and the applicant fails, a second attempt must be offered within 10 days. Regulators must publish the process, requirements, and necessary information on a publicly accessible website.
The rules are backed by administrative penalties. Under Ontario Regulation 286/25, a regulatory authority that contravenes its general labour mobility obligations faces a fine of C$25,000 for a first offence, $50,000 for a second offence within five years, and $110,000 for subsequent violations. Authorities that fail to meet reporting requirements can be fined up to C$11,000 per month for repeat offences.
The enforcement mechanism is unusual. Ontario has designated ”monitor ministries” – oversight bodies that review regulatory authorities’ labour mobility processes. If an authority fails to comply with its obligations, the monitor ministry can issue a compliance request. If the authority still does not comply, the ministry can initiate administrative penalties. In effect, regulators are being regulated.
David Piccini, Ontario’s Minister of Labour, Immigration, Training and Skills Development, framed the changes as an economic imperative when the regulations were announced: “By streamlining the process for certified professionals from other Canadian jurisdictions to work in Ontario, we’re opening doors for talent and driving economic growth.”
“By streamlining the process for certified professionals from other Canadian jurisdictions to work in Ontario, we’re opening doors for talent and driving economic growth.”
– David Piccini, Ontario’s Minister of Labour,
Immigration, Training and Skills Development
The practical impact extends to health care, where 16 regulated professions are covered by parallel reforms under the Regulated Health Professions Act. Sylvia Jones, Ontario’s Deputy Premier and Minister of Health, emphasised the urgency for physicians and nurses to start working sooner, noting that strengthening labour mobility helps “people get the right care, in the right place, where and when they need it”.
The infrastructure that does not yet exist
The policy is clear. The technology to support it is less so.
There is no evidence of an operational application programming interface or integrated digital verification system linking Ontario’s 50-plus regulatory authorities. Each operates independently, often with legacy systems built for a time when credential verification meant mailing paper files between offices.
The requirement that regulators publish information on publicly accessible websites is different from creating a centralised platform where applicants can track progress or authorities can verify credentials in real time.
The Financial Services Regulatory Authority of Ontario (FSRA), which oversees insurance agents, brokers, and adjusters, has implemented what it calls an “express lane” for out-of-province applicants.
But details suggest the process still involves manual document submission. FSRA has said applicants will be deemed certified once the regulator receives proof of a valid out-of-province licence, but there is no indication that verification happens through automated cross-jurisdictional checks.
The 10-day timeline is not flexible. Small regulatory authorities – those overseeing professions with fewer applicants and smaller budgets – may lack the staff or digital infrastructure to meet the requirement consistently. If an authority cannot process applications within the mandated period, it risks penalties.
The failure modes are predictable: identity verification delays, interprovincial data format incompatibilities, appeals that stall deemed certification while disputes resolve, and capacity constraints at small regulators that lack the administrative staff to handle surges in applications.
Australia is facing a similar challenge as it designs a national licensing system for electricians. The Productivity Commission has been explicit about the role of technology, pointing to the need for a national register and data‑sharing infrastructure to support real‑time verification. In practice, APIs that allow interoperability between agencies may prove as important as the legislation itself.
The commission estimated that improved labour mobility across licensed occupations could add 0.04 per cent to GDP per year. The economic benefit of national electrical licensing alone was projected at A$51 million to A$62 million annually.
Australia is working toward a single national law while Canada is harmonising 13 separate systems through federal and provincial legislation.
Australia’s approach differs from Canada’s in structure. It is working toward a single national law administered by state and territory regulators, whereas Canada is harmonising 13 separate systems through federal and provincial legislation.
But the underlying challenge is the same: how to verify credentials across jurisdictions quickly enough to matter without creating gaps that allow unqualified individuals to slip through.
The Electrical Trades Union in Australia has warned against a “lowest-common-denominator approach” that sacrifices safety for speed. That tension – between mobility and standards – is central to any regulatory coordination effort. If receiving jurisdictions cannot easily verify the accuracy of credentials from sending jurisdictions, they must either trust the home regulator’s processes or conduct their own checks, which delays the very mobility the reforms are meant to enable.
What regulators in other jurisdictions can learn
Canada’s experiment offers a few lessons that extend beyond its borders. One is that regulatory coordination at scale requires more than goodwill. Voluntary frameworks, no matter how well designed, depend on individual regulators choosing to participate. Binding requirements, enforced through penalties, shift the calculation.
But compulsion introduces a second constraint: capacity. Small regulators with limited budgets face different realities than large, well-resourced authorities. If compliance costs exceed what an authority can absorb administratively, coordination fails not through resistance, but through incapacity.
And notably, digital infrastructure cannot be an afterthought. The decision to regulate across multiple jurisdictions while maintaining safety standards depends on real-time data sharing. That means interoperable systems, secure APIs, and a willingness to invest in technology that most regulatory authorities have historically underfunded.
The UK, which lost automatic mutual recognition of professional qualifications when it left the European Union, has pursued a different model.
Rather than harmonising across professions, it has negotiated bilateral mutual recognition agreements on a profession-by-profession basis. An engineering Mutual Recognition Agreement (MRA) between the UK and the United States, signed in 2025, was estimated to be worth up to £999 million in increased exports over five years. A Canada-UK architecture MRA, signed in April 2025, created a streamlined path for certified architects to practise across jurisdictions.
The advantage of the bilateral model is precision. Each agreement can account for the specific standards, training requirements, and competency frameworks of a single profession.
The disadvantage is scale. Negotiating agreements one profession at a time is slow. Canada’s approach – covering 300 certifications under a single framework – is faster but depends on the assumption that comparable provincial standards are, in fact, comparable.
New Zealand offers a third model. It has approximately 180 to 200 regulatory systems, each with a designated stewardship agency. Rather than focusing primarily on labour mobility, New Zealand has invested in a Regulatory Management System that sits across individual systems to ensure quality and coherence. A 2023 joint report from the Treasury and the Public Service Commission considered establishing a dedicated regulation agency to strengthen cross-system coordination, though the focus was on regulatory design and performance rather than credential portability.
The gamble of temporary authorisation
The deemed certification period creates a temporary bridge – six months of authorised work while full registration completes. The gamble is that full registration processes can keep pace. If they cannot, the six-month window expires before an applicant moves from deemed to full status, forcing either a halt in work or an extension mechanism that has not yet been tested. That would undermine the very mobility the framework was designed to enable.
The penalties for regulatory non-compliance are designed to prevent delay. But they also create tension between autonomy and harmonisation. Professional regulators in Canada have traditionally operated with significant independence, setting their own standards based on public interest considerations specific to their profession. A framework that imposes timelines and fines regulatory authorities for failing to meet them shifts that balance. It prioritises mobility over discretion.
Whether that shift serves the public interest depends on whether the 10-day timeline forces regulators to streamline bureaucratic delays without compromising substantive review, or pressures them to approve applicants they would otherwise investigate further.
What comes next
The answer will not be clear for months. Ontario’s reforms are three weeks old. The federal act came into force on the same day. Early lessons will emerge through the first quarter of 2026 as regulators adjust processes, applicants test timelines, and monitor ministries begin oversight.
By the end of the year, there should be data on how many applications were processed within 10 days, how many resulted in full certification within six months, and how many triggered penalties.
What is already clear is that regulatory coordination at this scale is fundamentally an operational challenge rather than a policy one. The hard part is not deciding that mobility matters. The hard part is building the systems – legal, digital, and institutional – that make it possible without eroding the standards that justify regulation in the first place.
Whether the hypothetical engineer who received deemed certification on 10 days into the year still has authorisation to work in Ontario six months from now will depend on whether those systems can keep pace with the law that now requires them to.
