In February, Chris Pittens, Ontario’s Registrar of Collection Agencies, issued a bulletin to all registrants under the Collection and Debt Settlement Services Act. The bulletin advises that virtual office arrangements will, in most cases, not meet the legal requirements for collection agencies operating in Ontario. The Registrar further clarified that shared serviced office spaces, such as those offered by Regus, WeWork, and Servcorp, may qualify under the Act under certain conditions as indicated below.

The Ministry of Public and Business Service Delivery and Procurement has identified an increase in the use of virtual office arrangements by collection agencies as their registered address. While these arrangements may provide mail handling or occasional access to meeting space, they generally do not satisfy statutory requirements.

The bulletin reinforces that agencies must maintain a bona fide physical location in Ontario that is open during normal business hours, with staff physically present to interact with clients or the public. In addition, all business records must be immediately accessible on-site. While remote work remains permissible, it cannot substitute for the requirement to maintain a compliant physical office.

The Government Action Committee has been monitoring this issue and is bringing it forward to ensure that members are aware of the implications. Members currently relying on virtual office arrangements should be advised to reassess their compliance, particularly in advance of licence renewal or potential inspection.

RMA Government Action Committee