For centres and agencies · 8 min

The January 1, 2027 changes to O. Reg. 137/15

On January 1, 2027, O. Reg. 197/26 adds six things to the regulation: a written supervision policy that says when and how children are counted (s. 11(2)); a named person to act when the supervisor is off site in an emergency (s. 6.1(2)); a missing-child policy for centres and agencies, with centres holding a missing-child drill every three months (s. 68.2); training that covers every required policy (s. 58(1.1)); for centres, rules on septic access points, vehicle barriers, hazards and unauthorized entry (ss. 24.1 to 24.4), with the parent handbook describing the entry measures (s. 45(1)(a.1.0.1)); and, for home child care agencies, hazard, firearm and septic rules for each home (ss. 31 and 31.1). The rest of O. Reg. 197/26, including the duty to tell the licensee at once about a prohibition (s. 62(5)), has been in force since July 1, 2026. Nothing is filed with the Ministry for an existing centre; everything has to be written, trained and recorded.

Checked against e-Laws on Oct 2, 2026. Section numbers are O. Reg. 137/15 unless another instrument is named.

A written supervision policy, with counting rules (s. 11(2))

Section 11 already requires every child to be supervised by an adult at all times. The new subsection requires written policies and procedures that spell out how. They must say when, how and how often children are counted, with any differences for different age groups; the strategies for higher-risk moments the regulation names (moving between rooms and between indoor and outdoor spaces, washroom visits, arrivals and dismissals, field trips, gates in outdoor play spaces, parking lots, and places where sightlines are blocked such as play structures, staircases and spaces that wrap around corners); the steps to take when a child is unaccounted for; and who is responsible for each of these.

Most programs count at transitions already. The change is that the interval and the method have to be written down, and that the record of counts becomes evidence that the policy is followed.

A named stand-in for the supervisor (s. 6.1(2), centres)

Where a centre’s policies give the supervisor powers or duties, the policies must name one or more people who exercise them when the supervisor is not on site and an urgent situation needs someone on site to act at once. The name goes into the policies themselves, so a policy review is the natural place to add it.

Missing-child policies and drills (s. 68.2)

Both centres and home child care agencies must have written policies for an incident in which a child is missing: how to decide that a child is missing so that the steps start, the steps themselves and who does what, when to call emergency services, and when to notify parents. Centres must also hold a missing-child drill at least once every three months and keep a written record of each drill for at least 12 months. A missing child remains a serious occurrence under s. 38, reportable within 24 hours.

Training on every required policy (s. 58(1.1))

The staff training and development policy must now provide for training on each policy and procedure the regulation requires. For most programs this formalizes what the policy review already does; the difference is that the training itself has to be provided for in the policy and shown in the records.

Physical site rules for centres (ss. 24.1 to 24.4)

The four new site requirements and who they apply to
Section	Requirement	Centres licensed before 2027
24.1 Septic system access points	None inside the outdoor play space; any on the premises inaccessible to children, secured per the Building Code, with a secondary safety device.	The play-space rule applies from July 1, 2027, or not at all with a director’s exemption.
24.2 Motor vehicle impact protection	Safety barriers outside the centre that meet industry standards, with documentation; or an engineer’s written opinion that none is needed.	Does not apply.
24.3 Hazards	Best efforts to remove or reduce hazards; notify parents of a hazard and the steps taken, except routine ones managed by standard measures.	Applies.
24.4 Unauthorized entry	Measures to prevent unauthorized people entering while children are present; the parent handbook describes them (s. 45(1)(a.1.0.1)).	Applies.

Plans submitted for a new or altered centre must show the septic access points and where any safety barrier is or will be (s. 14(2)); a centre operated in a school for its pupils is exempt from ss. 24.1 and 24.2 (s. 12).

Home child care premises: hazards, firearms and septic access (ss. 31 and 31.1, agencies)

The current s. 31 (poisonous and hazardous items inaccessible, firearms and ammunition locked up) is replaced. From January 1, 2027 the agency must make best efforts to eliminate or mitigate hazards at each home — dangerous items, conditions or features that could foreseeably harm a child — keep firearms and ammunition locked with the key out of reach, and tell parents about any hazard and the steps taken, except routine ones managed by standard measures such as a locked cabinet or outlet covers (s. 31.1). Any septic access point at a home must meet the same criteria as a centre’s under s. 24.1(1)(b) (new s. 31). The supervision policy (s. 11(2)) and the missing-child policy (s. 68.2) apply to agencies too; the quarterly missing-child drill is for centres.

What to do before January

Write the supervision policy with the counting interval per age group and the higher-risk strategies; decide how counts will be recorded.
Name the supervisor’s stand-in in every policy that gives the supervisor a duty.
Write the missing-child policy; centres, schedule the first drill for January and the record that goes with it.
Add the new policies to the training policy and to the annual review, so every person signs them.
Centres: walk the site for septic access points, vehicle approaches, hazards and entry points, and keep the engineer’s letter or barrier documentation where an inspector can see it; add the entry measures to the parent handbook.
Agencies: walk each home with the provider for hazards, firearms storage and septic access points, record what was found and fixed, and write the parent notice.

Sources

O. Reg. 137/15 as consolidated on e-Laws (current to September 28, 2026; last amendment O. Reg. 197/26). This guide explains the regulation in plain words; it is not legal advice, and the Ministry’s program advisors decide compliance.