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Strategy for Continuous Improvement


Audits are required when the Commissioner specifies.

Between 2008 and 2010, the OFC required all regulatory bodies subject to the fair-access legislation to undergo an audit of their registration practices. To date, this is the only time that audits have been used. The purpose of these initial baseline audits was three-fold:

  • to determine regulators’ compliance with fair-access legislation
  • to identify registration practices that needed to be modified
  • to identify effective registration practices that could be shared between regulators

In 2013, in the spirit of continuous improvement, the OFC recognized that it needed to review its approach.

OFC staff members conducted extensive research and consulted with regulators, auditors, drafters of the fair-access legislation, the Ontario Internal Audit Division of the Treasury Board Secretariat, and experts in other provinces. This exercise yielded important findings.

As a result, the OFC now takes a more targeted approach, focusing on particular concerns that have already been identified and cannot be resolved in other ways.

Specifically, the OFC will require an audit on a case-by-case basis, when all of the following conditions are present:

  1. The OFC has identified an issue with a regulatory body’s registration practices that has left the OFC in doubt about whether the regulatory body is registering applicants in a way that is transparent, objective, impartial and fair. The OFC may have identified the issue in assessments or during regular monitoring of the regulatory body’s registration practices.
  2. The issue is persistent. The OFC has raised it with the regulatory body in writing on more than one occasion, and with the minister responsible for the regulatory body (with the regulatory body’s knowledge).
  3. An independent investigation is needed, because it offers a wider range of investigative techniques than the OFC has at its disposal, and because it would help the OFC determine whether the regulator is meeting its legislative obligations – and, if not, what changes need to be made.

The OFC’s audit guidelines document, Audits of Registration Practices: Guidelines for Ontario’s Regulatory Bodies, is an important resource. Based on the law, the guidelines identify the scope, standards and conditions for an audit and detail the eligibility criteria used in developing the roster of auditors.

Roster of Auditors

The OFC has authorized the following firms to conduct audits of registration practices:

February 2015


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