Rule explainer Not legal advice

Life insurance advertising rules in Canada

Read this before you publish, to find out which of the three things people call “the rules” actually binds you, and what each asks of a page on your site. Only one of the three is law, and only in one province.

The rulebookThere is no national advertising rule here. Your website is governed by a national conduct guidance, an industry guideline on illustrations, and your own province's law. The guidance says so itself: conduct of business in insurance is “the exclusive authority of the provinces and territories”. Sources 1 and 2, at the foot of this page.

How the rulebook assembled

April 28, 2009An industry guidelineCLHIA publishes Guideline G6 on illustrations: the insurers' own association setting a standard for its members. Widely followed, and not a statute.
September 2018A national expectationCCIR and CISRO publish the Fair Treatment of Customers guidance: every provincial regulator behind one set of expectations, one page of which is about promotion.
April 1, 2022Ontario makes it lawFSRA's unfair or deceptive acts rule takes effect, amended June 1, 2023 and again February 14, 2024. A rule with teeth, in one province.

Scope

Does it reach you?

Almost every licensed life agent in the country sits inside the national guidance. What differs is how much law sits on top, and the province on your licence decides that.

Who is coveredOne broad word covers everyone who is not an insurer. “Intermediary” is “given a broad meaning that encompasses agents and representatives and Distribution Firms”, and the guidance “applies to all Intermediaries that are authorized to do business within any jurisdiction”. Source 1.

Licensed to sell life insurance anywhere in Canada

The guidance reaches you

Independent, contracted through a managing general agency, or captive to one insurer: the word covers all of it, and the firm as well as the person. Read on.

Licensed in Ontario

Guidance, plus a rule with force

FSRA's rule is made under the Insurance Act and reaches your marketing directly. It is the one place on this page where the word “rule” does the work people assume it does everywhere.

Licensed in Québec, or in more than one province

The same floor, different law on top

The national guidance is common ground. Above it, the Autorité des marchés financiers, the Insurance Council of British Columbia and Alberta's regulator each add their own requirements, and Québec adds a language obligation nothing here addresses. Your counsel answers that, not a checklist.

The page was written by your insurer or your agency

Shared, which is not the same as somebody else's

Where several parties design and market a product, the guidance says fair treatment “is a responsibility that is shared amongst involved Insurers and Intermediaries”, and material designed by intermediaries “follows the same principles”. A brochure on your site is your promotion too.

What is covered

The guidance never mentions websites

There is no list of media to check yourself against, and looking for one is the first wrong turn. The section is called Product Promotion, it runs to one page, and it is medium-blind on purpose. Two lines elsewhere say why: disclosure holds “whatever distribution model and medium used”, and whether advice is being given is made clear “independent of the distribution model or the medium used”.

So a blog post, a downloadable guide, a re-hosted brochure and the text under a video are one category, and which of them counts is never the question. The useful question is the other one: has this page stopped describing a product and started recommending one to a particular reader. That line is real, and crossing it brings a different set of duties.

Promotion and adviceProduct Promotion is page 18. Advice is the section immediately after it, kept separate on purpose. Source 1.

Which rules reach it?

Worked examples

Worked from the guidance's own text. Where a real page lands is a judgement about your facts.

The core of it

Five tests, and one sentence over them

This is the whole of what the national guidance asks of promotional material: one expectation, then five things the information has to be. Shorter than its reputation, and the fourth and fifth are where a good page usually fails. Left, the guidance's own words. Right, what each means when the material is a page on your site.

Reading noteThe middle column is quoted from the Product Promotion section, page 18. The left margin marks where each line sits. Source 1.

Fair Treatment of Customers guidance, Product Promotion

Point at either side to link them

Verbatim

In plain English

p. 18CCIR and CISRO expect that product promotional material is accurate, clear, not misleading and consistent with the result reasonably expected to be achieved by the Customer of the product.

the test

To promote products in a fair manner, the information provided:

In plain EnglishOne sentence with five endings. They are cumulative rather than alternatives, and a page has to satisfy all five at once.

first

is easily understandable

In plain EnglishReadability is a compliance question here, not a style preference. A page that is accurate and impenetrable fails the first line.

second

is consistent with the coverage offered

In plain EnglishThe page has to match a contract the reader could actually buy from you. A general article on permanent insurance drifts out of this the moment it describes features your products do not have.

third

accurately identifies the Insurer

In plain EnglishName whose product it is. This catches the page written to sound as though your practice issues the policy, and it is broken by tidying a sentence far more often than by intent.

fourth

states prominently the basis for any claimed benefits and any significant limitations

In plain EnglishTwo obligations, both turning on one word. Say where a benefit comes from, say what limits it, and put both where the reader meets the claim rather than at the foot of the page.

fifth

does not hide, diminish or obscure important statements or warnings.

In plain EnglishThree verbs, and only the first is about deleting anything. The other two are about layout: eight point grey below the fold is a design decision the guidance treats as conduct.

Quoted text is the guidance's own. The right-hand column is our plain-English rendering, not part of the guidance. Source 1.

Vocabulary

Four words that carry the weight

Two from the national guidance, two from Ontario's rule. Most arguments about a draft turn out to be arguments about one of them.

Not misleading

Judged by the impression the page leaves, which is why a post whose every sentence is true can still fail. Emphasis, order and omission all feed it.

Prominently

Not whether the limitation is on the page. Whether it sits where the claim is. Placement is the whole content of the word.

Reasonable person

Ontario's test is what a reasonable person in the reader's position would think, not what you meant. Intention appears nowhere in it.

Reasonably expected

Does the material match the result a customer can reasonably expect? The yardstick behind every argument about projected values.

The number on the page

Guaranteed, or merely projected

Most Canadian life content that gets into trouble does it here, and by accident: a figure leaves an illustration, lands in a paragraph, and loses the column heading that said what it was.

On CLHIAGuideline G6, Illustrations, April 28, 2009, is published by the life insurers' own association. An industry standard members follow, not a statute, and nothing here treats it as binding law. The guideline text is members-only; the description alongside is CLHIA's own public summary. Sources 4 and 5.

What people think it says

Keep cash values and dividends off the website entirely.

Plenty of advisor sites are written this way, and it costs something: the reader goes and finds a worse explanation elsewhere. Nothing asks you to stay silent about how a participating policy works.

What it actually asks

Keep the two kinds of number visibly apart, and say what moves the second kind.

CLHIA describes its own guideline as calling for “clearly disclosing whether values or features in the policy are guaranteed or not guaranteed” and, where they are not, for disclosing “how and under what circumstances the non-guaranteed values may vary and what the effect may be on the policy”.

What a projected figure has to carry once it is out of the table and into a sentence: enough to place it

Which column it came fromGuaranteed by the contract, or projected on an assumption

The assumption behind itThe dividend scale or crediting rate the projection used

When that assumption was setScales are reviewed. An undated figure means nothing

Whose product it isThe insurer, named, because the third test asks for it by name

What happens if it movesThe direction and the effect, which is the guideline's second half

Where the full picture isA personalized illustration from the insurer, which an article is not

The failure is almost never the number. It is the verb next to it. “Grows to” and “reaches” describe a projection as though it were a schedule, and a reader who has never seen an illustration cannot tell the difference. “Is projected to reach, on the current dividend scale” is longer, and still true in three years when the scale has moved.

Where Canadian posts go wrong

Two sentences that will not survive a read

Both are ordinary sales language that reads fine out loud and does not survive being written down. The first promises a tax result the reader may not get. The second recommends a product to everybody at once, which is the opposite of what the whole regime is built on.

Why these twoTax treatment on a permanent policy depends on the policy, the owner and the Canada Revenue Agency's current position, none of which an article knows. Suitability is individual by definition. Source 1.

One claim, four ways to write it

Pick a wording

tax-free retirement income 100% tax-free shelter your money from the CRA may be tax-advantaged

Does not survive

“Build up the cash value and draw it later as tax-free retirement income.”

With no condition attached it promises a result that depends on the policy, the owner and the rules in force when the money comes out. Against a standard asking for material “consistent with the result reasonably expected to be achieved by the Customer”, this is the sentence doing the damage.

Does not survive

“100% tax-free growth inside the policy.”

The percentage makes it worse rather than more precise. It turns a conditional treatment into an arithmetic fact, and invites a reader to plan around a number nobody promised.

Does not survive

“Shelter your money from the CRA.”

Not really a tax claim at all. It is a claim about the tax authority, and it reads as though a product puts a reader beyond its reach. Being memorable is the problem: it is the line quoted back to you.

Survives

“Depending on your situation, some of the value may be accessible on a tax-advantaged basis. Your accountant should confirm how that applies to you.”

Longer, and true. The conditional wording is not a hedge; the treatment genuinely varies. Routing the reader to a tax professional is what your disclaimer block already says.

Examples, not a permitted list. Tax questions belong with a tax professional. Source 1.

The second sentence is “everyone needs whole life”, in any of its forms, including the soft ones: every family, every Canadian, the best policy for everyone. The guidance is built on matching a product to a customer's disclosed needs, and an article that has reached the conclusion for every reader has skipped the only part doing any work. The fix is not a hedge at the end. It is writing the piece around when the product fits and when it does not, which is also the version a reader trusts.

Ontario puts the same idea in harder language. Its rule reaches a person receiving “information, promotional materials, or advice in any form, including audio, visual, electronic, written and oral means” which a reasonable person in that reader's position would consider “inappropriate, inaccurate or misleading” about the terms or benefits of a contract, a claim, or “any comparison of contracts of insurance”. Note what is absent: any requirement that you meant to mislead. Source 3, section 8(1).

The duty nobody plans for

What happens when you find out a page is wrong

Every regime tells you to publish carefully. This one also says what to do afterwards, and that is the part with real operational consequences, because it lands on a page you wrote years ago and forgot.

The dutyOn becoming aware that promotional material is inaccurate or misleading, an insurer or intermediary “informs the party responsible for designing the material” and “has the material withdrawn”. A second duty follows in some cases. Source 1, page 18.

You have just learned that a live page is wrong

Guidance, page 18

Someone is relying on it Nobody has acted on it yet. One duty. A customer has acted on it. Two duties, and the second has a clock.

Starts the moment you become aware no fixed deadline

The first duty runs on knowledge, not on complaint: nobody has to write to you. If the page was designed elsewhere, telling whoever designed it is part of the obligation rather than a courtesy.

Once customers are relying on materially inaccurate information, the guidance adds notifying them and correcting it “as soon as reasonably practicable”. That is the only timing language in the section, and it is deliberately not a number.

The consequence people trip over: a site edited in place, keeping no copy of what a page said before, cannot show what a reader relied on. Source 1.

Which is a tooling decision, made long before anyone asks. How long you keep those copies, and what else your licence and your distribution agreement require, is a separate question with no single national answer. What records to keep →

One section about our software, then back to the rules

What Verand checks here, and what it does not

Everything above holds whether or not you buy anything. This is the inventory of how much of it software can see in a draft. The right-hand column is the longer one, and printing it is the point.

What it checks

Blocks growth or cash value written as guaranteed beyond what the contract guarantees, and recognises the contractual wordings as the exception they are.
Blocks an unconditional tax-free claim. The four wordings above are the real test: three are stopped, the conditional one passes.
Blocks “everyone needs whole life”. The insurance layer underneath treats that as a warning; for life it hardens into a block, because this is a line where suitability is regulated.
Blocks implied government endorsement and unsupported superiority claims, plus six more from the baseline. Two of those, “risk-free” and “zero risk”, release only on a written, logged reason.
Requires the Canadian disclaimer block, three cited sources with one from a primary Canadian regulator, and article schema. Twelve hard rules, two review rules.

What it does not

It does not check titles. Ontario and Québec restrict who may call themselves a financial advisor or financial planner. No title rule ships: nothing fires, not a block and not a warning. Check a title claim yourself, against your credentials.
It does not check French, or notice that a page needs a French version. Québec's language obligation is not encoded at all.
It does not read an illustration. The guaranteed-versus-projected separation is checked in your prose; a table or a screenshot goes through unexamined.
It does not carry the AMF's rules, or British Columbia's, or Alberta's. What ships is the national baseline, with Ontario's rule as its provincial source.
It does not decide whether a page is advice. That turns on what you were told about a reader, and that is not in the text.
It does not publish. Nothing reaches your site without a licensed person at your practice approving it, and no setting changes that.

Validated against CCIR/CISRO's and FSRA's rules. AI-researched and operator-reviewed. Your counsel confirms applicability. Not legal advice. How we label review →

Verand for Canadian life agents The disclaimer block, word by word →

Questions

The ones that come up

About the rules, not about our software. Each points at where the answer sits.

Is a blog post promotional material?

Treat it as one. The guidance names no media and draws no line between marketing and education, so a post about how a product works sits inside the same expectations as a page selling it. The distinction that does exist is between promotion and advice, and it turns on whether you are answering a particular person's disclosed needs.

Is CLHIA Guideline G6 law?

No. CLHIA is the industry association for Canadian life and health insurers, and its guidelines are standards members undertake to follow. Ignoring G6 is not itself an offence. Publishing a projected value as though it were guaranteed is a different matter: that runs into the not-misleading expectation in the national guidance and, in Ontario, into a rule with force behind it.

I am not in Ontario. Does FSRA's rule matter to me?

Not as law. Read it anyway: it is the clearest written statement of what the national expectations look like once a regulator has to enforce them, and it is built around outcomes rather than intentions. If your province's requirements are less explicit, that is not the same as lighter.

Can I put cash value numbers on the site at all?

Yes, and the sites that refuse are usually losing readers to worse explanations. What you cannot do is present a projected figure without saying it is projected, what assumption produced it and what would move it. With that attached, the number does useful work instead of quietly making a promise.

My agency wrote the page. Whose problem is it?

Shared, and Ontario is blunt about what that means. Its rule deems a director, officer, employee or authorized representative to have committed the act where they permit or acquiesce in it, or where they fail “to take all reasonable care in the circumstances to prevent” it. Not reading what goes out under your name is not a defence anywhere in the country.

Sources

Where every line came from

Primary sources only, each one opened rather than remembered. Quoted phrases are the source's own words. Everything else is our plain-English rendering, worth checking against the text rather than taking our word for it.

1Conduct of Insurance Business and Fair Treatment of Customers, September 2018. Product Promotion at page 18. CCIR and CISRO 2Unfair or Deceptive Acts or Practices Rule, effective April 1, 2022, amended June 1, 2023 and February 14, 2024. FSRA 3The amended rule as it now stands, effective February 14, 2024. Sections 1(4), 2(1) and 8(1) are quoted above. FSRA, PDF 4Guideline G6, Illustrations, April 28, 2009. The summary quoted above is CLHIA's own; the guideline itself is members-only. CLHIA 5CLHIA Guidelines, the full index, where G6's title and date are verifiable. CLHIA

Section references are to FSRA's Unfair or Deceptive Acts or Practices Rule as amended, effective February 14, 2024. Page references are to the CCIR/CISRO guidance. Last checked against these sources on September 17, 2026. Not legal advice, and not tax advice.

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