New ISC Registry Rules: What Ontario and Federal Corporations Need to Know

Did you know both corporations incorporated provincially under the Ontario Business Corporations Act and federally under the Canada Business Corporations Act are required to maintain registers in their minute books which specify the details of the individuals who control them?
 
Since January 2024, federally incorporated companies must file information about anyone controlling 25% or more of their shares with Corporations Canada annually and within 15 days of changes. Most ISC information (name, address, control details) becomes publicly searchable online, though birthdates and citizenship remain private, and home addresses can be protected by providing an alternative service address.

Non-compliance results in serious penalties: corporations face fines up to $100,000 and potential dissolution, while directors and officers risk fines up to $1 million and up to five years imprisonment. The registry aims to combat money laundering and tax evasion by increasing transparency about beneficial ownership of Canadian businesses.
 
Since January 2023, Ontario corporations must maintain an ISC register at their registered office using the same 25% control threshold as federal law. Unlike the federal system, Ontario’s register is not filed with the government or made public—it’s only accessible to law enforcement, tax authorities, and securities regulators for investigative purposes, although this may change in the future. Corporations must update it annually and within 15 days of changes. Penalties include fines up to $5,000 for corporations and up to $200,000 plus six months imprisonment for directors and officers who knowingly authorize violations.
 
At  LLF, we help clients comply with these requirements as part of our minute book maintenance.

Emmet Connolly, Partner, LLF Lawyers LLP