Registration Regulation Amendment Frequently Asked Questions

RCDSO is consulting on draft amendments to the Registration Regulation under the General Regulation (O. Reg. 205/94) of the Dentistry Act.

These proposed changes relate primarily to the divestment of RCDSO’s Professional Liability Program (PLP), which was approved by College Council in 2023. 

Visit our consultations page to learn more. 

Why are these changes being proposed?

While PLP is owned and operated (separately) by the RCDSO, there is complete certainty that all dentists have liability coverage. Once the program is no longer owned and operated by the RCDSO, the public will need assurance that every dentist has liability coverage.

Changes to the Registration Requirements under the General Regulation (O. Reg. 205/94) of the Dentistry Act are being proposed to address this.

The proposed changes to the regulation will require that dentists have liability coverage in order to register; and that there is a mechanism to suspend registration if coverage is not in place. The proposed changes will also support dentists’ return to practice if there is a lapse in liability coverage.

What are the proposed changes?

All registrants will be required to have professional liability protection in order to be registered or to renew registration. All registrants’ certificates of registration will be subject to a Term, Condition and Limitation (TCL), requiring that the registrant maintain professional liability protection in order to practise.

This is similar to the requirements of several other regulated health professionals (including Pharmacists, Physicians, Physiotherapists, Dental Hygienists, Dental Technologists and Midwives).

How will registered dentists find coverage?

Registered dentists will continue to have seamless liability protection for a period of time. RCDSO is building in a transition phase to the divestment process, so that once PLP moves to a third party, dentists will continue to be covered for a transition period, and they will not need to make any immediate changes. When the new provider is finalized, full information will be provided to the profession.

How will the College enforce coverage?

Dentists cannot practice if they do not have liability coverage. Under the proposed regulatory change, the College would be able to suspend a registrant who does not provide evidence that they hold professional liability protection, when requested. It would also permit the College to suspend a registrant who does not provide information required by the College (e.g., reporting information about their insurance policy on the annual renewal form).

The proposed change allows a suspension to be lifted by the Registrar during a 60-day grace period (without having to apply to the Registration Committee for reinstatement). Beyond these 60 days, if the issue is not corrected, the certificate of registration is automatically revoked, with an option to apply for reinstatement if eligible.

Should a dentist practise without the required protection, they may be subject to disciplinary action.

Will all registered dentists be required to have coverage, regardless of whether or not they practice?

Yes, just as it is today, all dentists are required to have professional liability protection. The current protection offered through PLP will continue throughout the 2025 calendar year, regardless of when the transition to a new entity takes place.

This is the beginning of the process for regulation amendments.

What are the next steps?

Consultation will be open on the RCDSO website for 60 days and all are welcome to respond to the survey and submit comments.

A summary of feedback and any recommended changes to the proposed amendments will be brought back to Council at the March 2025 meeting. The final regulation amendments will be submitted to the Ministry shortly afterward.

The Ministry of Health will post the regulatory change proposal on the Government of Ontario’s Regulatory Registry for comment for a 45-day period. Once consultation input has been reviewed and incorporated (where appropriate) regulations are drafted and then approved, or amended, by the Minister.

What will happen with the current annual membership fee amount?

RCDSO has collected fees for the 2025 year in the usual manner. Once the transfer takes place, RCDSO fees will be revised to reflect the change in operations of the PLP program and the impact of the transition on the College.

Will my liability fees go up once the transfer happens?

It is too early in the process to know what the new operator will charge for liability protection. One of Council’s expectations for the new operator is that the cost be fair and reasonable and comparable to market rates. There will likely be some increase in the fees for liability insurance.

Will minimum liability limits change?

Consistent with other Ontario health Colleges, RCDSO will look to mandate minimum limits. Currently, liability limits are $2 million which is consistent with most Canadian regulators’ requirements, although some require higher limits.

Updates to the College by-laws will be required to establish the requirement for minimum professional liability protection (such as minimum coverage amounts) to ensure that the public is protected. These by-law amendments will be brought forward to Council later in 2025.