Ontario PI Code of Conduct 2026: What Every Licensee Must Do

Where the code comes from and why it binds you

The Code of Conduct is not optional guidance. Under s. 53 of the Act, the Minister may, by regulation, establish a code of conduct, and it is a condition of every licence issued under the Act that a licensee shall comply with it. That code is O. Reg. 363/07. Section 1 of the regulation defines the trigger for discipline plainly: a licensee is in breach of the code of conduct if the licensee contravenes or fails to comply with the Regulation. Because compliance is written into the licence itself, a breach is not merely bad manners; it is a failure of a licence condition that exposes you to the complaint and investigation process. The regulator's authority to make these and related rules is set out in the Act at s. 54(1)(a) to (h) and s. 54(1)(i) to (t).

The positive duties on individual licensees

Section 2(1) of O. Reg. 363/07 imposes a list of duties on every individual licensee while working as a private investigator or security guard. The licensee must act with honesty and integrity, and must respect and use all property and equipment in accordance with the conditions of the licence. The licensee must treat all persons equally without discrimination on grounds that include sexual orientation, among others listed in the code. On the privacy side, the licensee must respect the privacy of others by treating all information received while working as confidential, except where disclosure is required as part of such work or by law. The code also requires cooperating with police where it is required by law.

• Act with honesty and integrity, per s. 2(1).
• Respect and use property and equipment per the conditions of the licence, per s. 2(1).
• Treat all persons equally, without discrimination on the listed grounds, per s. 2(1).
• Treat information received while working as confidential, except where disclosure is required as part of the work or by law, per s. 2(1).
• Refrain from exercising unnecessary force, per s. 2(1).
• Refrain from using profane, abusive or insulting language or actions, or actions that are otherwise uncivil to any member of the public, per s. 2(1).
• Cooperate with police where it is required by law, per s. 2(1).

The express prohibitions and their exception

Alongside the duties, s. 2(2) and (3) of the regulation set out conduct that is flatly prohibited. An individual licensee must not be unfit for duty, while working, through consumption of alcohol or drugs. The licensee must not conspire with another person, or aid or abet another licensee, in a breach of the code of conduct, and must not wilfully or negligently make a false statement or complaint against another licensee. The code also prohibits misrepresenting to any person the type, class or conditions of the licence. That last prohibition carries a narrow exception in s. 2(3): it does not apply to an individual licensee who is concealing his or her identity as a private investigator or security guard in order to carry out his or her duties, which recognises the reality of undercover investigative work. Refraining from behaviour that is either prohibited or not authorized by law is also required under s. 2(1).

How the code applies to business entities

The Code of Conduct does not stop at individual licensees. Sections 3(1) and 3(2) of O. Reg. 363/07 apply the code to licensed business entities, so a company that sells the services of private investigators or security guards is itself bound and can itself breach the code. In practice this means an agency cannot escape responsibility by pointing at an individual employee: the entity carries its own duties under the regulation. The test sometimes contrasts the individual duties in s. 2 with the business entity duties in s. 3 to check that you know both exist. Keep the structure in mind: s. 2 governs the individual on the ground, and s. 3 governs the licensed business behind them, with s. 1 defining breach for both.