Ontario Recruitment Licence

 Ontario Recruitment Licence: Complete Guide for Recruiters and Employment Agencies in 2025

Recruiters and staffing agencies play an essential role in connecting employers with qualified talent. However, in Ontario, this activity is now tightly regulated. Under the Employment Standards Act, 2000 (ESA) and Ontario Regulation 99/23, any business or individual involved in recruitment or temporary help placement must hold a valid Recruitment Licence or Temporary Help Agency (THA) Licence issued by the Ministry of Labour, Immigration, Training and Skills Development (MLITSD).

Failure to obtain the required licence can expose a business to substantial fines, public naming on the government’s non-compliance list, and even the inability to operate legally in the province.

Who Needs an Ontario Recruitment Licence?

You must apply for a recruitment licence if your business:

• Finds or attempts to find employment for others in exchange for compensation.

• Refers, recommends, or places candidates with employers (inside or outside Ontario).

• Works as an employment intermediary, headhunter, or staffing agency.

This requirement applies equally to Ontario-based recruiters and foreign corporations that recruit Ontario workers for jobs abroad. If a company recruits Ontario residents—even remotely—it must be licensed before engaging in such activity.

Licence Requirements and Documentation

Applicants must meet specific financial and integrity standards before approval. The Ministry requires:

• $25,000 irrevocable letter of credit payable to the Director of Employment Standards.

• Completed application form detailing business structure, officers, and directors.

• A criminal background check for each officer, director, and owner.

• Proof of business registration in Ontario (Corporation, Partnership, or Sole Proprietorship).

• Statutory declarations confirming the applicant’s good character and compliance with the ESA and other employment laws.

If any officer has previously violated the ESA or operated without a licence, the Ministry may deny or revoke the licence.

How to Apply for a Recruitment Licence in Ontario

Applications are submitted through the Ontario Business Licensing Portal, where businesses can create an account, upload supporting documents, and pay the required fees. The Ministry reviews the submission and may request clarifications or additional evidence before issuing the licence.

Once approved, the licence number must appear on all job postings, client communications, and public materials. Licences are valid for one year and must be renewed before expiration to continue operations legally.

Temporary Help Agency vs Recruitment Agency Licence

While both licences fall under the ESA, they serve different purposes:

• Recruitment Agency Licence – For businesses that refer or match job seekers to employers but do not employ those workers directly.

• Temporary Help Agency Licence – For businesses that hire workers themselves and assign them to client companies.

Some agencies may require both licences depending on their business model.

Penalties for Operating Without a Licence

Operating without a valid licence can result in:

• Administrative penalties and monetary fines.

• Cease-and-desist orders from the Ministry.

• Prohibition from providing recruitment services.

• Public disclosure of the violation on the MLITSD’s website.

Employers that knowingly use unlicensed recruiters may also face penalties.

Compliance and Renewal Obligations

Licensed agencies must maintain continuous compliance with the ESA and related regulations. Key obligations include:

• Keeping detailed records of recruitment activities, contracts, and fees.

• Renewing the licence annually and updating the Ministry of any business changes.

• Ensuring no worker is charged recruitment fees—this is strictly prohibited in Ontario.

• Maintaining the letter of credit for the duration of the licence.

Failure to comply can lead to suspension or revocation of the licence.

Why Legal Guidance Matters

The recruitment-licensing process can be complex, particularly for foreign corporations, multi-jurisdictional agencies, or businesses expanding into Ontario. Incorrect filings, incomplete documentation, or misunderstanding of the ESA can delay approval or lead to costly compliance issues later.

At Hadri Law, our Employment and Business Lawyers assist:

• Ontario and foreign recruiters applying for their first licence.

• Staffing agencies navigating dual licensing (recruitment + THA).

• Businesses responding to Ministry compliance inquiries.

• Applicants appealing licence denials or revocations.

Our firm provides step-by-step legal support—from preparing the application package and drafting the required declarations to ensuring your letter of credit meets statutory criteria.

How Hadri Law Can Help

As a Toronto-based business law firm focused on corporate, commercial, and employment law, Hadri Law understands the unique challenges recruitment businesses face. We offer:

• Full legal representation throughout the licensing process.

• Compliance audits to ensure adherence to ESA requirements.

• Strategic advice on structuring your operations to meet Ontario standards.

• Ongoing legal support for renewals, disputes, and government inspections.

Our goal is to protect your business while enabling you to focus on connecting talent with opportunity.

Get Started Today

If your business recruits, refers, or places workers in Ontario, you must comply with the new recruitment-licensing rules. Don’t risk penalties or business interruption.

Contact Hadri Law today to schedule a consultation. We’ll help you determine whether your operations require a licence, prepare your application, and guide you through every compliance step with confidence.