1.2 Mandatory Training, Licensing Pathways & Digital Credentials

Before you can work as a private investigator in Ontario, you have to clear a fixed sequence of legal gates: the eligibility rules in the Private Security and Investigative Services Act, 2005 (PSISA), the training and testing rules in Ontario Regulation 26/10, and ServiceOntario's application requirements. The licensing test often asks which gate comes first, who issues what, and which document proves which requirement. This section walks through that sequence in order.

Mandatory Eligibility Requirements (PSISA s. 10)

Under section 10(1) of the PSISA, no person is eligible to hold a licence unless they:

1. Possess a clean criminal record (defined in s. 10(5));
2. Are 18 years of age or older;
3. Are entitled to work in Canada; and
4. Have successfully completed all prescribed training and testing.

The age, work-entitlement and training requirements apply to individuals. The clean-record requirement applies to every licensee, including the officers, directors and partners of a business entity. ServiceOntario's application page also requires a Criminal Record and Judicial Matters Check for every applicant.

What "clean criminal record" means

Section 10(5) says a person has a clean criminal record if they have not been convicted of a prescribed offence or, if convicted, have received a pardon (record suspension) under the Criminal Records Act. The prescribed offences are listed in Ontario Regulation 37/08 (Eligibility to Hold a Licence — Clean Criminal Record):

• Table 1 lists Criminal Code offences. It has 81 numbered items, one of which (item 51) has been revoked, leaving 80 offences.
• Table 2 lists two Controlled Drugs and Substances Act offences: trafficking (s. 5(1)) and importing or exporting (s. 6(1)).

Two exam traps come from this list:

• Not every conviction is on it. Common assault (s. 266), uttering threats (s. 264.1), theft under $5,000 and possession for the purpose of trafficking (CDSA s. 5(2)) are not prescribed. They do not automatically disqualify an applicant.
• An unlisted conviction is still not a free pass. Under s. 13(2), the Registrar may refuse a licence if past conduct gives reasonable grounds to believe the person will not act lawfully and with integrity, or if refusal is in the public interest. The ministry's study guide explains that such files are reviewed individually and the applicant may be given an opportunity to be heard.

Ongoing duties after a conviction

Eligibility must continue for the whole licence term:

• O. Reg. 361/07, s. 5: an individual licensee must notify the Registrar in writing within five days after being convicted or found guilty of an offence prescribed by O. Reg. 37/08.
• PSISA s. 10(2): a person who stops meeting a section 10(1) requirement must stop working under the licence and return it to the Registrar within five days, excluding Saturdays, Sundays and public holidays.
• PSISA s. 11(1)(c): every new or renewal application includes a declaration listing convictions and findings of guilt, unpaid provincial-offence fines and unresolved charges. A charge alone does not trigger the five-day conviction notice, but it must be declared on the next application.

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Mandatory Basic Training (O. Reg. 26/10)

Mandatory training and testing took effect on April 15, 2010, when the Training and Testing Regulation came into force. Under O. Reg. 26/10, s. 2(2), a private investigator licence cannot be issued unless the applicant has:

• completed a training program that complies with the ministry's Training Syllabus for Private Investigators (the version cited in the regulation is dated January 20, 2015); and
• passed the ministry's licensing test for private investigators.

Who may deliver the training (O. Reg. 26/10, s. 2(3))

• a public university;
• a college of applied arts and technology;
• a career college registered under the Ontario Career Colleges Act, 2005;
• a licensed business entity (an agency); or
• a registered business entity that employs the applicant or has made the applicant a conditional offer of employment.

Anyone else is prohibited from holding themselves out as able to provide qualifying training (s. 3(2)). Training providers enrol with the ministry's testing provider on its Training Registration Venue.

How the course may be delivered

The syllabus sets a minimum of 50 in-class hours. Outside-class hours are pre-reading only. Students may complete a classroom course or a web-based course. A web-based course must offer real-time interaction with an instructor if the student needs it, and live instructor-led video-conference courses qualify. Only students who attend the whole course qualify to take the test.

The official eight-section syllabus

The two largest blocks are investigative techniques (14 hours) and criminal and civil law (12 hours). This study guide is organized around all eight sections.

Private investigator vs. security guard training

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The Training Completion Number (TCN)

When a student finishes an approved course, the training provider uploads the completion to the ministry's database and the system emails the student a Training Completion Number (TCN). The TCN:

• is required to book the licensing test;
• is the test-result identifier used by ServiceOntario and the ministry; and
• does not expire, according to the testing provider. A candidate who fails can rebook without retaking the course.

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Applying to ServiceOntario

After passing the test, the candidate applies to ServiceOntario, which processes licences for the ministry. Applications may be made online (up to 15 calendar days to process) or by mail (up to 30 calendar days).

Health cards, Social Insurance Number cards and firearms licences are not acceptable ID. Applications that include health card or SIN information are returned. Fees are non-refundable, and a returned application must be fixed within 90 calendar days.

Out-of-province licence holders

O. Reg. 26/10, s. 2(7) exempts an applicant who holds a permanent private investigator licence from another province or territory that was issued after training and a test. ServiceOntario also processes "As of Right" applications under the Ontario Labour Mobility Act, 2009: a decision is due within 10 business days, failing which the applicant is deemed certified for six months while the review continues.

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Licence Term, Digital Credentials and Renewal

• Term: under O. Reg. 367/07, an individual licence issued after January 30, 2012 expires on the holder's second birthday after the day it is issued. Each renewal runs two years and stays linked to the birth date.
• Digital only: ServiceOntario no longer issues physical licence cards. Approved applicants download the digital licence through their Ontario.ca Login and may print it.
• Carrying: you must carry the digital version or a printed copy and be prepared to show it on request. Section 2.3 explains the PSISA s. 34 duty in detail.
• Renewal window: a licence may be renewed up to 90 calendar days before it expires. Information changes (name, address, contact details) are free. Changing licence type costs $80 and cannot be done within 90 days of expiry.
• No grace period: working after the licence expires means acting without a licence, contrary to PSISA s. 6.

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Individual Licences vs. Agency Licences

An individual licence lets a person act as a private investigator, but PSISA s. 6 also limits for whom they may work. They must be employed by a licensed business entity, a registered employer or an employer that is not required to register, or be the sole proprietor or a partner of a licensed business entity. Under s. 7, anyone who sells private investigator services needs a business (agency) licence. A self-employed investigator who takes clients in their own name therefore needs both licences.

A business that employs its own in-house investigators but does not sell their services to the public must register as an employer under s. 5 instead of holding an agency licence. Its investigators still need individual licences (s. 31).

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Dual Licences

An individual may hold both licence types as a dual licence ($160). The candidate must complete both training programs and pass both tests in separate sessions. PSISA s. 12, paragraph 3 then sets the key operational rule: regardless of the licences held, a person may not act as a security guard and a private investigator at the same time.