Overview of changes

Under Ontario Regulation 292/25, a modernized framework to support human trafficking investigations is being introduced within Ontario’s accommodation sector.

Key updates

Expanded guest register requirements

Applies to both traditional providers (for example, hotels, motels, resorts) and online accommodation platforms, replacing the outdated Hotel Registration of Guests Act.

Guest registers are a critical investigative tool as traffickers often use accommodations to move victims and survivors while maintaining anonymity. These requirements aim to:

  • enhance investigative capacity
  • promote transparency
  • safeguard appropriate handling of sensitive data (balancing public safety with privacy protections)

Removal of the outdated obligation to post room rates

Better aligns with current business practices and technologies.

Standardized processes for law enforcement access

Police may obtain guest data via a production order in non-urgent cases or demand immediate access in urgent cases (for example, imminent harm to a victim or risk of evidence destruction).

New regulatory requirements

As of January 1, 2026, accommodation providers and online accommodation platforms must now record in a register:

  • name and primary residence of the guest
  • primary phone number of the guest who provides their name and primary residence
  • vehicle information (if parked on site, and for online accommodation platforms, unless unknown at the time of reservation)
  • billing address (for online accommodation platforms, instead of primary residence)

This guest information must be maintained for 6 years from the end of the fiscal period in which it was recorded.

This aligns with Canada Revenue Agency requirements for financial recordkeeping, streamlining compliance and reducing administrative burden for businesses.

Specific requirements for online accommodation platforms

Recognizing the distinct business models of online accommodation platforms, the regulation includes tailored requirements to make compliance straightforward and practical:

  • vehicle information is collected at the time of reservation, unless unknown
  • a billing address is recorded in place of primary residence, aligning with existing platform practices

These adjustments enable consistency in information recorded in a register while respecting operational differences across the sector.

Penalty for non-compliance

To encourage compliance, the penalty for failing to meet register requirements has been increased to $5,000.

Hotel operators, already required to maintain guest registers, may need to update operational practices for complete and accurate data collection.

Law enforcement access and oversight

Police access is limited to cases involving the identification or location of individuals who may be victims and survivors of human trafficking.

Police may demand immediate access without a production order in urgent cases (for example, imminent harm or risk of evidence destruction).

Reporting

To promote transparency, officers must report every use of urgent demand powers, within 30 days of each occurrence.

Police chiefs must submit annual reports by April 1, which must be made publicly available by June 1 every year. These reporting requirements are the same as those under the Missing Persons Act, 2018 and support public accountability.

Background

Ontario Regulation 292/25 under the Accommodation Sector Registration of Guests Act, 2021 (ASRGA) establishes requirements to maintain guest registers across both traditional accommodation providers and online accommodation platforms that are consistent across the sector.

The Act and regulation:

  • support Ontario efforts to combat human trafficking through its $345-million strategy for 2025-2030
  • replace outdated provisions to reflect modern business practices and technology
  • introduce standardized processes for law enforcement to access guest information in connection with human trafficking investigations
  • set clear rules for information maintenance, promoting accountability and transparency in how sensitive data is handled by operators across Ontario

The Act and regulation take effect on January 1, 2026.