For centres and agencies · 9 min

What a licensing inspector checks

A licensing visit looks at records more than rooms. The program advisor wants to see that the written policies exist and are followed, that every adult was screened before starting and is still in date, that ratios were kept and counted, that drills happened, that serious occurrences were reported within 24 hours, and that every record the regulation names has been kept for three years. Most of it is predictable, which is why it can be ready before the visit.

Checked against e-Laws on Oct 1, 2026. Section numbers are O. Reg. 137/15 unless another instrument is named.

Policies: written, implemented, trained

The regulation requires written policies and procedures on a long list of subjects: supervision of volunteers and students (s. 11.1), sleep (s. 33.1), serious occurrences (s. 38), anaphylaxis (s. 39), medication (s. 40), the program statement and its implementation (ss. 46, 49), safe arrival and dismissal (s. 50), staff training (s. 58), police record checks (s. 65), fire safety (s. 68) and emergency management (s. 68.1), among others. Section 6.1 then adds the part that inspections turn on: the policies must be implemented at every centre and home, and the licensee must have a written way of monitoring compliance with them and recording contraventions.

In practice the advisor asks three questions of each policy. Does it exist in writing? Has every employee, volunteer and student reviewed it, with a record of the date? And does the day-to-day evidence (the logs, the drills, the postings) show it is actually followed? The regulation leaves the review schedule to the licensee’s own monitoring policy under s. 6.1(7); the Licensing Manual expects each policy to be reviewed with every person before they interact with children, and most programs set an annual review after that. A policy nobody has signed, or a sign-off sheet with no dates, fails the second question whatever the schedule says.

People: screened before they start, still in date

For every employee, the advisor expects a vulnerable sector check obtained before the first day (s. 60), a new one on or before every fifth anniversary and an offence declaration in each year between, due within 15 days of the anniversary (s. 62). Volunteers and students need the same before they interact with children. Everyone counted in a ratio, every supervisor and every home child care provider needs a valid standard first aid certificate with infant and child CPR (s. 58(2)). Health assessments and immunization as directed by the local medical officer of health come before the first day too (s. 57). The details are in the screening guide.

Ratios and group sizes, and the counts that prove them

Section 8 and Schedule 1 set the ratio, the maximum group size and the proportion of qualified employees for each age group; s. 8.1 and Schedule 4 do the same for family age groups. The advisor checks the daily attendance records required by s. 72(3) and (4) against the staff schedule: who was in the room, when, and whether the arithmetic held, including during the reduced-ratio windows at arrival, departure and rest. A room that was over ratio for twenty minutes in March is visible in those records; so is a room that was always within ratio. Ratios and group sizes walks through the rules.

Drills, approvals and inspections

A fire drill every month, with a written record of each drill and of every alarm and equipment test kept at least 12 months (s. 68(1)(e), (2)); the fire procedure approved by the local fire chief and posted in every room used for children (s. 68(1)(a), (c)).
Emergency management policies covering roles, an off-site meeting place, parent communication and recovery (s. 68.1).
From January 1, 2027: a missing-child policy and, for centres, a missing-child drill at least once every three months with the record kept 12 months (s. 68.2). See the 2027 changes.
The annual playground inspection and the daily and monthly checks the playground standard requires (s. 24), medication records (s. 40), menus and allergy postings (s. 43), insurance (s. 71).

Incidents and serious occurrences

Two records sit side by side. The daily written record (s. 37) summarizes any incident affecting a child’s or a staff member’s health, safety or well-being, with the parent notified. A serious occurrence (s. 38) is reported to the Ministry within 24 hours of the licensee or supervisor becoming aware of it, a summary is posted for at least 10 business days, and the summary is kept for three years. The advisor reads the daily record for anything that should have been a serious occurrence, and reads the serious-occurrence file for the times. The 24-hour guide covers what counts.

Sleep

Children under 12 months are placed for sleep in line with the Public Health Agency of Canada’s safe sleep statement unless a physician says otherwise in writing; sleeping infants and toddlers get direct visual checks by someone physically beside them; and the written sleep policy says how often the checks happen and how they are documented (s. 33.1). The advisor asks to see the check records for a recent week. Sleep supervision has the detail.

Records: the three-year rule

Section 72 lists what must be on file for every child, from the signed enrolment application to immunization, medication instructions and the people who may pick the child up, and requires daily attendance with arrival and departure times. Section 82 then says that every record the regulation requires is kept in a secure place for at least three years from the date it was made and is available to an inspector at all times, on paper or electronically. Records and retention lists them.

Having it ready

The visit goes quickly when the records are in one place and dated. A practical order: the licence and the program statement; the policy set with the review dates for every person; the screening and first aid dates per person; the drill log; the approvals and inspections; the daily records for the last month; the serious-occurrence file; the children’s files. Anything the advisor cannot find in the room counts as not kept, however carefully it was done.

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.