Regulation
Who regulates it, and what they expect
Insurance is provincially regulated employment. Even where OSFI supervises your solvency, your staff are covered by the employment standards, occupational health and safety and human rights law of each province you operate in - insurance is not on the federal list, so the Canada Labor Code does not apply to you as it does to the bank in the same tower. In Ontario that means 11 consecutive hours off each day, 8 hours between shifts, 24 consecutive hours off each week and a 30-minute eating period after 5 hours. Claims and market-conduct rules are consumer protection, not worker safety.
Who regulates it
Your workforce is regulated province by province - in Ontario by the Ministry of Labor under the Occupational Health and Safety Act and the Employment Standards Act, with the Human Rights Tribunal and the WSIB. OSFI and regulators such as Ontario's FSRA supervise solvency and market conduct; neither sets employee hours or fatigue rules. Banks and telecom carriers are federally regulated employers; insurers are not.
Your obligations
You owe the provincial general duty to take every precaution reasonable in the circumstances for a worker's protection, and in Ontario a written health and safety policy reviewed at least annually where more than five workers are regularly employed. Employment standards set the hours floor: 8 hours a day and 48 a week absent written agreement, 11 consecutive hours off each day which cannot be waived, 8 hours between shifts, 24 consecutive hours off each week or 48 in two weeks, and a 30-minute eating period after 5 consecutive hours. Human rights law requires you to accommodate a diagnosed sleep disorder to undue hardship.
Consequences
Ontario's Occupational Health and Safety Act carries fines of up to $2,000,000 for a corporation, $1,500,000 for a director or officer and $500,000 for any other individual, the last two with up to 12 months' imprisonment, plus a $500,000 minimum for a repeat corporate offence causing death or serious injury within two years. Employment standards contraventions draw notices of contravention at $250 per affected employee, rising to $500 and then $5,000 for repeats within three years, with prosecution to $100,000 on a first corporate conviction. Failure to accommodate a diagnosed sleep disorder is decided separately by the Human Rights Tribunal, which can order lost wages and damages for injury to dignity.
Penalties
Ontario maximums in force in 2026: under the Occupational Health and Safety Act, $2,000,000 for a corporation, $1,500,000 for a director or officer and $500,000 for any other individual, with a $500,000 minimum fine for a repeat corporate offence causing death or serious injury within two years. Employment standards penalties run $250 per affected employee, then $500, then $5,000 for repeats within three years. Ontario's maximums are the highest in Canada.
On the record
No Canadian court, coroner, investigator or regulator has published a finding linking fatigue to an incident in insurance. The duty to manage fatigue still sits within the general duty in federal and provincial occupational health and safety law.
Sources: Ontario Occupational Health and Safety Act s.66 and the ministry's guide to the Act; Ontario Employment Standards Act guide (hours of work, enforcement); Government of Canada list of federally regulated industries; OSFI and FSRA mandates.