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Canadian legal system

PSISA Expansion 2026: Will Locksmiths, Armoured Vehicle Workers, and Security Consultants Need a CRJMC?

Ontario's Private Security and Investigative Services Act (PSISA) has governed security guards and private investigators since 2005. Now, a comprehensive government review could expand that regulation to cover locksmiths, security consultants, armoured vehicle services, and commercial property managers with in-house security operations.

If you work in one of these fields - or you're thinking about entering them - this guide covers what the proposed changes mean, who could be affected, and what a CRJMC requirement would look like in practice.

What Is PSISA?

The Private Security and Investigative Services Act, 2005 is the Ontario law that regulates the private security industry. It sets licensing requirements, training standards, and a code of conduct for security guards and private investigators.

Under PSISA, anyone working as a security guard or private investigator in Ontario must:

  • Complete mandatory training through a Solicitor General-approved provider.

  • Pass a Ministry test.

  • Obtain a Criminal Record and Judicial Matters Check (CRJMC).

  • Apply for and maintain a licence through the ServiceOntario Licensing Portal.

  • Renew their licence every two years, including a new CRJMC each time.

The Private Security and Investigative Services Branch (PSISB) - part of the Ministry of the Solicitor General - enforces the Act, conducts compliance inspections, and maintains the list of disqualifying criminal offences.

Why Is Ontario Reviewing PSISA Now?

The Act hasn't been substantially updated since it came into force. In the 20 years since, the private security industry has changed significantly:

  • Rapid growth: The number of licensed security personnel in Ontario jumped 75% between 2020 and 2025, rising from 92,615 to 162,320 individuals.

  • More licensed agencies: Licensed security organizations increased 30%, from 850 to 1,115 over the same period.

  • New service types: Roles like security consultants, in-house corporate security teams, and specialized locksmith services have grown, but many fall outside PSISA's current scope.

  • Public safety concerns: High-profile incidents involving unlicensed or poorly regulated security-adjacent workers have raised questions about whether the Act covers enough of the industry.

The Ministry of the Solicitor General launched a public consultation to gather feedback on how PSISA should be modernized. The consultation period closed on January 21, 2026. The Ministry is now reviewing submissions and could announce regulatory amendments in the coming months.

Who Could Be Affected by the Expansion?

The consultation specifically asked whether PSISA regulation should extend to these groups:

Locksmiths

Locksmiths have access to homes, businesses, and vehicles as part of their work. Unlike in some other provinces, Ontario currently does not require locksmiths to hold a security-related license or undergo a criminal record check. The consultation proposes bringing locksmiths under PSISA, which would likely mean mandatory licensing, training standards, and a CRJMC requirement.

Security Consultants

Security consultants advise businesses, property managers, and institutions on physical security, risk assessment, and loss prevention. They often have access to sensitive security plans and building layouts. Currently, they can operate without any license under PSISA unless they also perform guard or investigative duties. Expanding the Act would bring them under the same regulatory framework.

Armoured Vehicle Services

PSISA already addresses armoured vehicle services to some degree, but the consultation proposes broadening and clarifying the regulatory scope. Workers who transport cash, valuables, or sensitive documents in armoured vehicles may face more comprehensive licensing and background check requirements.

Commercial Property Managers with In-House Security

Large commercial landlords and property management companies sometimes employ in-house security teams rather than contracting licensed agencies. The consultation raises the question of whether these in-house operations should also fall under PSISA, which would require their security staff to be individually licensed and background-checked.

What Would a CRJMC Requirement Mean for These Professions?

If the expansion goes through, workers in the newly regulated professions would likely need to:

Obtain a CRJMC before applying for a licence. A CRJMC is a Level 2 police record check under Ontario's Police Record Checks Reform Act, 2015. It reveals criminal convictions, outstanding charges, judicial orders (peace bonds, probation orders, prohibition orders), and certain non-conviction dispositions.

Clear the disqualifying offences list. The PSISB currently maintains a list of 83 criminal offences that automatically disqualify an applicant. A conviction for any of these results in denial. However, the consultation also proposes giving the Provincial Registrar discretion to evaluate convictions on a case-by-case basis - considering the severity of the offence, time elapsed, and evidence of rehabilitation - rather than applying a blanket bar.

Renew their CRJMC periodically. Security guard licences currently require renewal every two years, including a fresh CRJMC. A similar cycle would likely apply to newly regulated professions.

Budget for the cost. A CRJMC through a local police service in Ontario costs between $40 and $85+, with processing times of 2 to 8 weeks. Online providers like CRJMC.net offer results in as fast as 15 minutes for $49.95.

Other Key Proposals from the Consultation

The PSISA review covers more than just expansion. Here are the other major proposals:

Discretionary Conviction Review

Currently, the 83 disqualifying offences operate on a binary pass/fail basis. The consultation proposes giving the Provincial Registrar discretionary authority to evaluate convictions individually. If adopted, this would be a significant change for applicants with older or less serious convictions who are currently barred automatically.

Use-of-Force Reporting

A proposed requirement would require security guards and agencies to report any use-of-force incident within 30 days. This would create more accountability and help the PSISB identify patterns or compliance issues.

Uniform and Vehicle Standards

The consultation proposes clearer rules requiring security uniforms to be clearly distinguishable from police uniforms and security vehicles to be easily distinguishable from police vehicles.

Fast-Track Licensing for Veterans and Former Police

A proposed fast-track pathway would recognize existing training and background checks for former police officers and Canadian Armed Forces veterans, potentially reducing their licensing requirements.

Strengthened Enforcement

The consultation seeks input on strengthening the Registrar's authority to enforce the code of conduct and to address compliance violations, including those involving unlicensed operators.

Timeline: What Happens Next?

Here's where things stand as of March 2026:

Public consultation opens

Status:

Completed (late 2025)

Consultation period closes

Status:

Completed (January 21, 2026)

Ministry reviews submissions

Status:

In progress

Proposed regulatory amendments published

Status:

Expected 2026

New regulations come into force

Status:

TBD

The Ministry has not announced a specific date for publishing results or proposed amendments. Based on typical Ontario regulatory timelines, draft amendments could be released later in 2026, with an additional comment period before final approval.

If you work in a profession that could be affected, now is the time to prepare. Getting a CRJMC in advance gives you a head start if licensing requirements are introduced.

How Ontario's Security Industry Has Changed Since 2005

To put the proposed expansion in context, here's how the industry has evolved since PSISA was first enacted:

Licensed security personnel

2005 (approx.):

~50,000

2020:

92,615

2025:

162,320

Licensed security agencies

2005 (approx.):

~500

2020:

850

2025:

1,115

Approved training providers

2005 (approx.):

N/A

2020:

331

2025:

181

Compliance inspections (annual)

2005 (approx.):

N/A

2020:

~300

2025:

452

Industry compliance rate

2005 (approx.):

N/A

2020:

~54%

2025:

60%

Sources: PSISB 2024-25 Annual Report, REMI Network

The jump from 92,615 to 162,320 licensed personnel in five years - a 75% increase - shows both the growing demand for security services and the scale of the regulatory challenge the PSISB faces. Expanding PSISA to cover additional professions would add even more individuals to this system.

How to Get a CRJMC in Ontario

Whether the expansion affects your profession now or in the near future, here's how the CRJMC process works:

Option 1: Local Police Service

Contact your local municipal police service or the Ontario Provincial Police (OPP). Most services offer in-person and online submissions. Processing times range from 2 to 8 weeks and costs vary by municipality ($40 to $85+).

Option 2: Authorized Third-Party Provider

Since July 2024, the PSISB accepts CRJMC results from authorized third-party providers for security guard and PI licence applications. CRJMC.net, powered by Triton Canada, is an authorized provider offering:

  • Results in as fast as 15 minutes.

  • Flat fee of $49.95.

  • Fully online process - no appointments or travel.

  • Accepted by PSISB for security guard and PI licence applications.

  • Available Canada-wide.

If the PSISA expansion goes through, third-party CRJMC results will likely be accepted for the newly regulated professions as well, following the same model already in place for security guards and PIs.

FAQs

Is PSISA expansion confirmed?

No. The proposals are based on the public consultation that closed January 21, 2026. The Ministry is reviewing submissions and has not yet announced specific regulatory changes. However, the fact that the government initiated a formal consultation signals serious intent.

When would the new rules take effect?

No date has been announced. If the Ministry moves forward with amendments, there will likely be a comment period on draft regulations, followed by a transition period before enforcement begins.

I'm a locksmith. Do I need a CRJMC right now?

Not yet. There is currently no legal requirement for locksmiths to obtain a CRJMC or hold a PSISA licence. However, if the expansion is adopted, you would need one. Some locksmiths are choosing to get a CRJMC now to show clients they've been background-checked, even before it's legally required.

What about security consultants who already work with licensed agencies?

If you're employed by a licensed security agency and perform guard or investigative duties, you already need a licence and a CRJMC. The proposed expansion would affect independent consultants and those who advise on security without performing guard or investigative work directly.

Would the 83 disqualifying offences apply to the new professions?

If the expansion follows the existing PSISA framework, yes. However, the concurrent proposal for discretionary conviction review could change how those offences are assessed for all applicants, including in the newly regulated professions.

What's the difference between a CRJMC and a CRC?

A CRC (Criminal Record Check) is a Level 1 check that shows only convictions. A CRJMC (Criminal Record and Judicial Matters Check) is a Level 2 check that also includes outstanding charges, judicial orders, and certain non-conviction dispositions. Since February 2024, the PSISB requires a CRJMC for all security licence applications.

Next Steps and Resources

The PSISA expansion is still in the consultation-and-review phase, but if you work in one of the potentially affected professions, preparation is straightforward:

  • Get informed. Review the Ontario government's PSISA consultation page for the full scope of proposed changes.

  • Get a CRJMC. Whether it's required now or may be soon, having a recent CRJMC gives you a head start. You can order one online at CRJMC.net and get results in as fast as 15 minutes.

  • Stay updated. Watch the PSISB's website for announcements about regulatory amendments.

  • Check your record. If you have a criminal history, understanding what appears on a CRJMC - and whether a record suspension might help - is worth doing before any licensing requirement takes effect.

Additional Resources

N

Nate Kane

Security Expert & Author

Expert in security and background check procedures, providing comprehensive guides and insights into the certification process.
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