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A CMRAO licence is permission from Ontario’s condominium management regulator for one named person, or one named firm, to handle what running a condominium corporation actually involves. That is other people’s money, contracts signed in the corporation’s name, and documents a buyer’s lawyer will rely on. Most boards treat a CMRAO licence as a yes or no answer. It is not one.
It is two licences, one held by the firm and one held by the individual. For the individual it also comes in a class. That class decides what the manager assigned to your building may do without someone else’s approval. Boards reviewing proposals for condo management services usually check the firm and stop there. So here is what general and limited each allow, and what your board should verify in the public register before it signs anything.
What a CMRAO Licence Is, and Who Has to Hold One
A licence is not a quality award, and it is not one document. Ontario regulates the firm and the individual separately. It also regulates a specific set of activities rather than property management in general. That set is narrower than most boards assume.
Two Licences, and Why Your Board Checks Both
No one may provide condominium management services in Ontario unless they are licensed as a condominium management provider or as a condominium manager. That is the licence requirement for condo managers in Ontario, and it creates two licences rather than one. The provider licence belongs to the firm, because the firm holds the trust account, employs the managers and signs the management agreement. The manager licence belongs to one individual, because the judgment being regulated belongs to a person.
A licensed provider also may not employ an unlicensed person to do work that requires a licence. So the firm’s own licence is on the line for whoever it puts in front of your board.
A firm has to designate one of its licensed managers as its principal condominium manager, and having that designation in place is a condition of the firm’s licence. That makes a vacancy in the role a licence problem rather than a staffing inconvenience. A board that checks the firm and forgets the person has done half a check. A licence check is one part of a wider screen for whether a condo management company is legitimate.
What Counts as Condominium Management Services
The licence attaches to particular work, not to a job title. The law counts collecting or holding common expense contributions and other amounts payable to the corporation. It also counts exercising powers and duties the corporation or its board has delegated, which is the half boards underestimate. That covers making payments to third parties for the corporation, negotiating or entering contracts for it, and supervising the employees or contractors it hires.
That is the list that triggers the licence. It is why a landscaper is not a manager, however much of your property they touch. It is also why the person who collects your common expense cheques might be.
Who Writes These Rules and Who Enforces Them
Ontario’s Condominium Management Services Act creates the licensing regime, and the CMRAO is the authority that administers it. The Government of Ontario sets the position out plainly in Ontario’s own guidance for condo owners: licensing has been mandatory for condo managers and condo management providers since November 1, 2017. The regulator also keeps a public register of both.
The working detail sits in regulation underneath that framework. The classes, the conditions attached to each one, the exemptions and the contents of the register are all set there. Manager licensing and complaints about a manager sit with the CMRAO, so that is where a licence question goes.
General vs Limited: What Each Class Lets Your Manager Do
The regulation lists the classes as limited, general and transitional general. For a board, limited is the working entry class and general is the unrestricted one. The restrictions on a limited licence land in the places a board feels most: the reserve fund and the status certificate.
What Needs the Supervisor’s Approval, and What Is Off Limits Entirely
A limited licensee may not provide condominium management services except under the supervision of a supervising licensee. The remaining restrictions split into work a supervisor can authorize and work no authorization reaches, which are the conditions Ontario’s regulation puts on a limited licence.
These need the supervising licensee’s prior approval:
- A limited licensee cannot spend more than $500 of the client’s money, not including the reserve fund, without the prior approval of the supervising licensee.
- A limited licensee cannot enter into, extend, renew or terminate a contract for the client without the supervising licensee’s prior approval.
- A limited licensee cannot give an owner or a mortgagee something the corporation is required to give them without the supervising licensee’s prior approval.
These are off limits entirely, with no approval route at all:
- A limited licensee cannot make expenditures out of, invest, or otherwise make dispositions of the client’s reserve fund.
- A limited licensee cannot sign status certificates on behalf of a client, so ask who signs your condo status certificate when your usual manager is away.
What a General Licence Allows
The condition on a general licence is about employment. A general licensee may not let more than one licensed management firm employ them without the consent of all the firms employing them. That consent has to be in the form the registrar approves. A limited licence carries the same employment condition, so that is not a difference between general and limited.
None of the limited-licence restrictions apply to a general licensee. A general licensee can work without a supervising licensee, can sign status certificates, and is not restricted by the regulation from acting on the reserve fund. For contracts and for spending the corporation’s money, a general licensee does not need another licensee’s prior approval. A general licensee may also be the firm’s principal condominium manager.
Boards ask a fair follow-up: can we hire a manager directly instead of going through a firm? A general licensee employed by no more than three condominium corporations, who is not an independent contractor, does not have to be employed by a management firm. A licensed condominium manager is otherwise required to be employed by a condominium management provider, and that exemption is written for general licensees.
Who Supervises Whom, and Why You Should Ask for the Name
A supervising licensee is a general licensee, or a holder of one of the older transitional general licences, who supervises someone with a limited licence. The consequence is the useful part: a limited licensee cannot be supervised by another limited licensee. Somewhere above the manager assigned to your building there has to be a named general licensee who is answerable for the approvals.
Ask for that person’s name and licence, in writing, before the contract is signed. A board that knows its manager’s class but not the supervisor’s name cannot tell who is actually authorizing its spending.
A general and a limited licence differ in a narrow set of places, and every one of them is something your board deals with: who supervises the manager, what the manager is allowed to spend and sign, and who can hold the firm’s principal manager role.
| What your board cares about | Limited licence | General licence |
| Working without supervision | Cannot provide condominium management services except under the supervision of a supervising licensee | No supervision condition, and a general licensee can be the supervising licensee for someone with a limited licence |
| Signing your status certificates | Cannot sign status certificates on behalf of a client | The regulation places no such restriction on a general licensee |
| Spending the corporation’s money | Cannot spend more than $500 of the client’s money, not including the reserve fund, without the supervising licensee’s prior approval | No spending threshold of this kind in the regulation |
| Touching the reserve fund | Cannot make expenditures out of, invest, or otherwise make dispositions of the client’s reserve fund | Not restricted by the regulation from acting on the reserve fund |
| Signing contracts for the corporation | Cannot enter into, extend, renew or terminate a contract for the client without the supervising licensee’s prior approval | May contract for the client without a supervisor’s approval |
| Being the firm’s principal condominium manager | Not one of the classes that may hold the role | Eligible, because the regulation requires that role to be held by a general licensee or by a holder of one of the older transitional general licences |
The Transitional General Licence You Will Still See Named
Older material still names the transitional general licence, and boards arrive asking about it. When licensing began, the regulation deemed experienced managers into a transitional general licence so the work could continue while the new regime came in. The regulation then bars renewing that licence or reapplying for it after May 31, 2022.
So the classes your board will meet in practice are limited and general. The regulation still refers to the older transitional general licences where it describes who may supervise a limited licensee. It names them again where it describes who may be a firm’s principal condominium manager.
How Someone Earns a General Licence, and Why It Matters to Your Board
Your board is not choosing a licence class, so why care how the general class is earned? Because it is the one signal in the register that the person has done the work before. They have already run an AGM, a budget night and reserve work with somebody else accountable for the outcome.
What the Entry Class Requires
For a limited licence, the applicant must be at least 18 years of age, must meet the application form requirements, and must pay the fees. They must also complete the educational and examination requirements, if any, that the registrar specifies. The gate is modest because the class comes with a supervisor attached.
The courses and exams behind each class are set by the regulator and have changed since licensing began, so what matters for your board is the class on the licence and the conditions attached to it. Auditing a manager’s coursework is not where your board’s time pays off.
The Step Up to a General Licence
The applicant must have at least two years of work experience under the supervision of one or more supervising licensees, obtained within the five years before applying. They must also already hold a limited licence, and must have completed the educational and examination requirements within that same five-year window. The experience itself has to be certified by the supervising licensee or licensees.
A general licence is a record of supervised work that another licensee put their own name to.
What That Supervised Experience Has to Include
The regulation does not leave the experience open to interpretation. It has to include that the applicant has:
- planned and participated in meetings of a client’s board of directors;
- planned and participated in meetings of owners, including at least one annual general meeting;
- participated in preparing a budget for a condominium corporation and presented it to the board;
- interpreted a client’s financial statements and presented them to the board;
- prepared and presented reports to a client’s board;
- overseen the maintenance or repair of units, common elements or client assets.
A board reading that list is reading its own calendar. That is why the class matters to your board.
How to Check a CMRAO Licence in the Public Register
This is the part a board can finish in ten minutes, and the part most boards skip. Run it as two searches rather than one: the firm, then the person. The register is the authoritative place to look, because the registrar is required to publish there rather than in a third-party directory.
Where to Look, and What to Search For
Start at the CMRAO public register and search the firm by its legal or licensed business name. Then search the individual assigned to your building by name. The register carries each licensee’s complete legal name and, where they are licensed in another name, the name they are licensed in. So a firm trading under a brand can still be found.
Every manager and every management firm working in Ontario has to appear in that register. What the register lists is licences, not every person who works on your property. Some roles are exempt from licensing altogether, so the person doing a particular job in your building is not always someone the register will list.
What the Register Has to Show You
The register has to show you the licence number and expiry date, the class of the individual’s licence, any conditions on it, and the contents of a final discipline order against that licensee. For a firm, it also has to show the name of the firm’s principal condominium manager, and its business address, email and telephone where the registrar knows them.
The record reaches past current status, which is what the registrar has to publish about every licensee. It also records a proposal by the registrar that has not yet been dealt with, a suspension, a refusal to renew, and a revocation. It records a cancellation at the licensee’s request, a current charge, and a finding of guilt as well.
How to Read the Conditions on a Licence
A description of the conditions on a licensee’s licence is one of the things the registrar is required to publish. Read it before you read anything the firm sent you.
Conditions are where the specific signal is. A condition is a restriction the registrar attached to that one licensee and not to the class. So two people holding the same class can carry different conditions. That is the reason to read the entry in front of you rather than reasoning from the class alone.
The class on an individual’s entry tells you what approvals your manager will need. That tells you how quickly your board can actually get a decision in August, when half the directors are away.
How Long a Record Stays on the Register
The regulation sets minimum publication periods, and they differ.
- A cancellation at the licensee’s request, a refusal to renew, and a revocation each stay available for at least two years.
- A suspension stays available for at least two years after the suspension has ended.
- A finding of guilt stays up for at least five years after the finding.
- A discipline or appeals order stays up for at least two years after the order was made.
These are minimum publication periods, not a guarantee that older history is still showing. So a clean entry today is not the same as a clean history. If a firm’s history matters to your decision, ask the firm directly and put the answer in the file.
The Verification Checklist Your Board Can Work Through
Verification is a sequence, not a glance. Work through it in this order, and keep the result in the corporation’s records with the date you checked it.
- Search the register for the firm and confirm it holds a condominium management provider licence.
- Search the register for the individual assigned to your building and note the class on their licence.
- If that class is limited, get the name of the supervising licensee in writing, and check that person in the register too.
- Check the name of the firm’s principal condominium manager in the register and confirm it matches the name the firm gave you. Having that designation in place is a condition of the firm’s licence, so a mismatch or a vacancy is a licence problem and not a staffing detail.
- Note the expiry date on both licences and diarize them.
- Read what the register says about conditions on both entries before you read the proposal.
- Look for a registrar’s proposal, a suspension, a refusal to renew, a revocation, a charge, a finding of guilt, or a discipline order.
- Ask who signs your status certificates when your usual manager is away.
- Ask for the firm’s errors and omissions and fidelity certificates and put them in the contract file; that is a contract question, whatever the licence says.
- Re-check the register whenever your assigned manager changes, not only when the contract is signed.
We run this at the start of an engagement rather than when a question comes up. The licence and class of the assigned manager go into the corporation’s file, along with the name and licence of the supervising licensee where one applies. Expiry dates go on the same calendar that carries the reserve fund study and the CAO filing dates.
What the Licence Does Not Tell You
A licence is a minimum standard. It says the person is permitted to act. It does not say they are good at it, and everyone presenting to your board has one. Two firms with identical register entries can run your building very differently, and nothing the register publishes will tell them apart.
So weigh what the register cannot tell you, in terms your board can test. Ask how many properties the assigned manager carries, who actually attends your board meetings, and how long reporting takes after month end. Ask what happens to an owner’s request while that manager is on vacation, and how often the firm has changed your manager in the past three years. Get those answers in writing, because a firm that cannot put a number on its own portfolio load has told you something already.
Ask any firm you are considering for its errors and omissions and fidelity coverage, and put the certificates in the contract file. That is a contract question, and a reasonable one, whatever the licence says.
The licence does give you one thing beyond permission. It gives you a code of conduct the manager can be held to.
What Your Board Can Hold a Licensed Manager To
This is the leverage boards do not know they have. A licensed manager is bound by a code of ethics that every licensed condo manager in Ontario has to follow. There is also a route for a board that is being ignored.
The Duties a Board Can Point To
The code of ethics every licensed condo manager is bound by sets its duties out in usable terms. A licensee must treat every person they deal with in the course of offering or providing condominium management services fairly, honestly and with integrity. A licensee must endeavour to treat all persons equally, without discrimination or harassment, and to provide reasonable accommodation for persons with disabilities. And a licensee must provide conscientious, courteous and responsive service and demonstrate reasonable knowledge, skill, judgment and competence.
That last duty is the one boards actually use. It is what you point to when a manager stops returning calls or fumbles a routine obligation. It is not a customer service preference. It is enforceable.
Where a Complaint About a Manager Goes
A complaint about a licensee goes to the registrar. The registrar can attempt to mediate or resolve it, or give the licensee a written warning that action may follow if the conduct continues. The other options include requiring further educational courses, referring the matter to the discipline committee, and taking action against the licence.
Most complaints never reach a hearing. The middle options are the common outcomes, which is worth knowing before your board decides whether to complain or simply to re-tender.
What the Discipline Committee Can Order
A discipline committee hears whether a licensee failed to comply with the code of ethics. On a finding of non-compliance it can order further educational courses, and it can order a provider to arrange and fund courses for the managers it employs. On the same finding it can also impose costs and impose a fine.
$25,000 is the maximum fine the discipline committee may impose on a licensee for failing to comply with the code of ethics. It is not a penalty for unlicensed practice, and it is not a court fine. An appeals committee can overturn, affirm or modify that order.
A finding against a licensee ends up on that licensee’s own entry in the register once the appeal period has passed, so you do not need to go hunting through decisions to see whether your manager has one.
Who May Work on a Condominium Without a Licence
The exemption list is where small corporations and self-managed boards get misled. The principle is worth holding onto: an exemption turns on what the person is actually doing, not on what they are called. A title does nothing on its own.
The Roles the Regulation Exempts
The regulation exempts particular roles, and each one is exempt only while acting within its own authority.
- The professionals: a person authorized to practise law or provide legal services, an architect, a licensed public accountant or Chartered Professional Accountant, an engineer, and a registered insurance broker, each acting within that authority.
- The appointed and the financial: a receiver appointed by the court, an inspector or an administrator appointed under Ontario’s condominium law, a person authorized to conduct a reserve fund study, and banks, credit unions and loan and trust corporations.
- A licensed security guard doing the collecting or supervising work within their licence, who promptly delivers any money collected to the corporation or its licensed manager.
- An employee of a licensed provider or of the corporation, where the authority to collect has been delegated in writing to the position they hold, and who promptly delivers any money collected to the corporation or its licensed manager.
- Anyone who provides only construction, repair and maintenance services to the corporation, including landscaping and cleaning.
Being Small Does Not Put Your Corporation Outside the Regime
Nothing in the exemption list turns on the number of units in the corporation. There is no small-corporation exemption, and no threshold below which the licence stops mattering. A small townhouse corporation sits inside the same regime as a tower on Yonge Street.
The substance test matters more than the list. In deciding whether someone is exempt, a court or tribunal looks at the real substance of the person and what they actually do. It may disregard the outward form. Labels do not create an exemption. Calling the person who collects your fees a coordinator or a volunteer does not change what the work is.
What Self-Management Means for Licensing
A person elected or appointed as a director or an officer of a condominium corporation is exempt, including a director who receives compensation under a by-law. That exemption falls away where the person is providing condominium management services for compensation or reward or the expectation of such.
Paying one of your own directors to run the building is the arrangement that compensation clause is written about. A board in that position should not assume the director exemption covers it. Get it looked at before you rely on it. The wider choice between self-managing or hiring a management firm turns on more than licensing.
What Happens If the Firm or the Manager Is Not Licensed
Boards tend to assume the risk here is a fine their own corporation will pay. It is not. The risk is a contract that does not protect them and a counterparty nobody can discipline.
Why an Unlicensed Firm’s Fee Claim Sits on Weak Ground
A proceeding for payment for condominium management services, brought by someone who was not licensed or exempt at the time they provided those services, can be stayed on a motion. So a board should not assume an unlicensed firm’s invoice is an ordinary enforceable debt. It is also prohibited to hold yourself out as a condominium manager or a condominium management provider, or to perform their functions, without a licence.
For an individual convicted of an offence under Ontario’s condo management licensing rules, the maximum penalties on conviction are a fine of up to $50,000 or imprisonment for up to two years less a day, or both. For a corporation or other entity, the maximum fine on conviction is $250,000. These penalties fall on the person or entity convicted of the offence, which in these cases is the operator providing services without a licence.
That sounds like leverage. Read it the other way as well. A board in a contract with an unlicensed firm is in a contract whose fee side may not hold up. That is not the same as a contract that protects the corporation.
Why an Unlicensed Manager Is Still Your Board’s Problem
Your corporation is left with a manager no regulator can discipline on your behalf. The exposure sits with your board’s own duty to act with care, diligence and skill.
Your board does not set that standard. It is a director’s duty of care under Ontario’s condominium law: a director must exercise the care, diligence and skill that a reasonably prudent person would exercise in comparable circumstances.
The duty belongs to your board whoever you hire. An unlicensed manager does not lower the standard your board is held to. It only removes the regulator who could have been leaned on. What your board of directors is responsible for does not shrink because the manager’s paperwork is missing.
When a Licence Changes in the Middle of Your Contract
Verification is not a one-time act at signing. Two things move while your contract runs. Each licence reaches its own expiry date on its own schedule, and the registrar can act on a licence at any point in between.
Expiry Dates Sit on the Licence Itself
Each licence carries its own expiry date, and the register shows it, so check the date on the licence in front of you rather than assuming a renewal month.
A past date does not always mean a dead licence. Where a licensee applied for renewal in time and paid the required fee, the licence is treated as continuing until the renewal is granted or the registrar refuses it in writing. So a date that has passed is a question to ask the firm, not a conclusion to draw.
A Temporary Suspension Can Take Effect Immediately
The registrar can refuse to renew, suspend or revoke a licence, and that process starts with a proposal by the registrar. The register shows that proposal while it is still outstanding.
There is also an exception, and it is the reason to look. Where the registrar proposes to suspend or revoke a licence and considers it in the public interest, the registrar can order a temporary suspension that takes effect immediately. The registrar can also cancel a licence at the licensee’s own written request. All of it shows in the register.
So re-check the register when your manager changes rather than only at signing. A manager whose licence lapses or is suspended cannot lawfully keep acting for you. The firm has a problem of its own if it keeps that person in the role. So put it to the firm in writing and ask who is covering your file and what licence that person holds. Send it to the firm’s principal condominium manager, and note the date you checked the register in your records.
Where This Leaves Your Board
The register tells your board what a manager is permitted to do. It does not tell you who will actually be assigned to your building next quarter, or how the firm is staffed behind that person. That is the question to ask next.
CPO Management has managed residential and commercial condominium properties across the GTA for more than 15 years. The portfolio runs from residential and commercial condominiums to co-ops and co-ownership buildings, office and industrial properties, and community and recreation centres.
Our condominium managers hold CMRAO licences. We tell a board the class of the manager assigned to it, and the name of the supervising licensee where one applies. We also say up front who signs your status certificates when your usual manager is away. If your board is reviewing proposals or rethinking the arrangement it has, our condominium management services start from that kind of disclosure. You can talk to our team about what your building needs.
Frequently Asked Questions
A CMRAO licence is permission from Ontario’s condominium management regulator for one named individual, or one named firm, to provide condominium management services. The law defines those services as collecting or holding the corporation’s money and other amounts payable to it, and exercising powers and duties the board has delegated. That delegated half includes paying third parties, contracting for the corporation and supervising its employees and contractors. The firm’s licence and the individual’s licence are separate, and your board checks both.
A limited licensee works under the supervision of a supervising licensee, and needs that person’s prior approval for contracts and for spending above the threshold the regulation sets. A general licensee does not. The limited class also carries bars that no approval lifts: signing status certificates for a client, and acting on a client’s reserve fund. A general licensee can hold the firm’s principal condominium manager role as well.
No. A limited licensee cannot sign status certificates on behalf of a client, and no supervisor’s approval changes that. Ask the firm who signs yours when your usual manager is away, and get the name of the general licensee who will do it. That is a question worth settling before a sale is pending rather than during one.
No one can apply for it or renew it, because the regulation closed both routes after May 31, 2022. It was the grandfathering route when licensing began, which is why older material still describes it as something a manager could obtain. For your board, the practical consequence is that the classes you will meet are limited and general. The regulation still names the older transitional general licences when it describes who may supervise a limited licensee and who may hold a firm’s principal manager role.
Size makes no difference. Nothing in the exemption list turns on the number of units, and there is no small-corporation exemption. A small corporation sits inside the regime exactly like a large one. Whether anyone needs a licence turns on who is doing the work, not on how many units you have.
Directors and officers of a condominium corporation are exempt, including a director who receives compensation under a by-law, unless the person is providing condominium management services for compensation or reward or the expectation of such. That trigger is the whole question for a self-managed board. A volunteer board doing its own administration sits inside the exemption. A board that pays one of its own directors to run the building should have the arrangement looked at before it relies on the exemption.
Search the public register twice: once for the firm, by its legal or licensed business name, and once for the individual assigned to your building. Read the class on the individual’s licence, any conditions on either entry, and the expiry dates. Then read anything the register shows about a proposal, a suspension, a charge or a discipline order. If the manager holds a limited licence, get the supervising licensee’s name in writing and check that person too.
A complaint about a licensee goes to the registrar, whose options run from mediation and a written warning to requiring further educational courses. The registrar can also refer the matter to the discipline committee, which can impose a fine of up to $25,000 on a licensee for failing to comply with the code of ethics. Before going that route, put the problem in writing to the firm’s principal condominium manager with a deadline, because most of these end at that step.