Getting a Payday Lender or Loan Broker Licence in Ontario - The CRJMC Requirement
If you want to run a payday-lending or loan-broker business in Ontario, you have to be licensed under the Payday Loans Act, 2008 first. Both lenders and brokers need a licence, and operating without one is an offence. One step in the application catches new applicants off guard: the criminal record check.
Here's the practical part up front. When a corporation applies, it has to provide a Criminal Record and Judicial Matters Check (CRJMC) for each officer and director as part of the licence application and consent to disclosure. The Ministry doesn't tie you to one provider - you obtain the checks yourself - so you can order them online in about 15 minutes each through crjmc.net for $54.99, and submit them with your application.
This article covers who needs a licence, why the Registrar runs the check, the CRJMC requirement and how many you'll need, the cost picture, and what happens at renewal.
Who has to be licensed
The Payday Loans Act, 2008 requires all payday lenders and payday loan brokers to be licensed. The Registrar - within the Ministry of Public and Business Service Delivery and Procurement - issues the licence and a certificate for each location. (This is a common point of confusion: payday lending is licensed by this Ministry, not by FSRA, which handles mortgage and insurance licensing.)
If you apply as a corporation, the Act sets some structural requirements: your officers and directors must be at least 18, at least one officer or director has to live in Ontario, you need at least one physical office in Ontario (a personal residence doesn't count, even for online-only lenders), and you must keep a separate bank account for the payday-loan business. A sole proprietor must also be at least 18.
Why the Registrar runs the check
Payday lending is built on handling other people's money and financial information, and the Act exists to protect a vulnerable group of borrowers. So before issuing a licence, the Registrar has to be satisfied the people behind the business are suitable - which is where the background check comes in. The Registrar can refuse, suspend, or revoke a licence, and can refuse to renew one, where suitability is in question.
The stakes are personal, too: officers and directors who fail to take reasonable care to prevent a corporate offence can themselves be fined up to $50,000 and face imprisonment, and corporations can be fined up to $250,000. Getting the licensing right from the start matters.
The CRJMC requirement
The check the application calls for is a Criminal Record and Judicial Matters Check - the middle of the three police-check levels defined under the Police Record Checks Reform Act, 2015 (PRCRA). It's a step up from a basic Criminal Record Check (which shows convictions only) and is not the deeper Vulnerable Sector Check (payday lending isn't a vulnerable-sector role).
The important detail is that it's one CRJMC per officer and director, not a single check for the business. A designate applying on behalf of a corporation provides a CRJMC for each officer and director, along with their consent to disclosure of personal information. A three-director corporation needs three checks; add a fourth director and you add a fourth check.
Timing - order it close to when you apply
Police record checks have a shelf life, and licensing bodies generally won't accept a stale one - the common standard across Ontario regulators is that a check must be dated within the last six months. Confirm the exact freshness window on the current application form before you order, but the safe approach is the same one that works everywhere: get the checks done in the weeks before you file, not months ahead, so they're current when the Registrar receives your application.
What's on a CRJMC
A CRJMC shows criminal convictions for which a record suspension hasn't been granted, certain Youth Criminal Justice Act findings within their disclosure limits, absolute and conditional discharges within their windows, and outstanding charges, warrants, peace bonds, and other current judicial orders.
It does not show most withdrawn or stayed charges, or most non-conviction information - those can appear, in narrow circumstances, only on a Vulnerable Sector Check. A single old, disclosed matter doesn't automatically end an application; the Registrar weighs suitability, and full disclosure matters far more than a perfectly clean sheet. One thing to watch: Bill 75 (the Keeping Criminals Behind Bars Act, 2025) could, if it becomes law, keep some summarily-prosecuted hybrid offences visible for longer.
What it costs
There are two cost buckets - the Ministry's licensing fees, and the checks themselves.
Payday lender / broker licence fee
Set by the Ministry - confirm current amount
Police-issued CRJMC
~$40-$70 each, days to weeks
local police service
Because you need one CRJMC per officer and director, the check cost multiplies with the size of your board - budget accordingly. The licence is valid for one year and renews annually, so this is a recurring part of running the business, not a one-time hurdle.
Why an online CRJMC is the practical route here
Because the Ministry doesn't impose an exclusive provider and simply asks you to bring a CRJMC for each officer and director, the only things that matter are speed, cost, and getting the right document. An online CRJMC wins on all three.
crjmc.net issues the exact check the application asks for, online, in about 15 minutes after identity verification, for $54.99 - with no appointment and no waiting on a police backlog. When you have several officers and directors to clear at once, doing it online in parallel is far faster than booking each person into a police counter. And it's the quick answer when you appoint a new officer or director mid-cycle and need their check without holding up the change.
Renewal and changes
Your licence is valid up to its expiry date and must be renewed before then to keep operating. Just as important, you have to notify the Registrar in writing within five days of changes to your officers or directors (among other things). When a new officer or director comes on, that's a new suitability event - so build a fresh CRJMC into the onboarding, the same way you would for the original application.
What to do next
Confirm your licence type - payday lender, loan broker, or both - and whether you're applying as a corporation or sole proprietor.
Line up the structural pieces - an Ontario office (not a residence), at least one Ontario-resident officer or director, and a separate payday-loan bank account.
List every officer and director who needs a check.
Order a CRJMC for each - online at crjmc.net, about 15 minutes, $54.99 each - close to when you'll file.
Submit the application with the checks and consent forms, and pay the fee.
Keep copies, and notify the Registrar within five days of any officer/director change.
Renew annually, before the expiry date.
Quick Q&A
Does each officer and director really need their own check?
Yes. A corporation provides a CRJMC for each officer and director, not one check for the whole business.
Do loan brokers need a licence too, or just lenders?
Both. The Payday Loans Act, 2008 requires payday lenders and payday loan brokers to be licensed.
Is this licensed by FSRA?
No. Payday lending is licensed by the Ministry of Public and Business Service Delivery and Procurement, not FSRA.
Does the Ministry make me use a specific check provider?
No. You obtain the CRJMCs yourself, which is why ordering online through crjmc.net is the fast, low-cost route.
How recent does the check have to be?
Police checks generally have to be recent - the common standard is within six months. Confirm the exact window on the current application form, and order close to when you apply.
We're adding a new director next month. Do they need a check?
Yes. You must notify the Registrar of the change within five days, and a new officer or director is a fresh suitability event, so plan on a CRJMC for them.
What's the difference between a CRJMC and a basic criminal record check?
A CRJMC adds judicial matters - outstanding charges, certain orders - on top of convictions. It's the level the application calls for.
Will an old conviction automatically sink the application?
No. The Registrar weighs suitability; honest, complete disclosure matters far more than a spotless record.
Does a withdrawn charge show up?
Generally not on a CRJMC.
Get started
If you're applying for - or renewing - a payday lender or loan broker licence, you can get a CRJMC for each officer and director online right now and have it back in minutes.
Start your CRJMC - 15 minutes, $54.99
Order one for each officer and director close to when you'll file, keep copies, and submit them with your application.
Sources: Ontario - A guide for payday lenders (ontario.ca/page/guide-payday-lenders), Payday Lenders and Loan Brokers Licence Application and Consent to Disclosure of Personal Information (forms.mgcs.gov.on.ca, form 002-12119), Payday Loans Act, 2008 and Ontario Regulation 98/09 (General), Police Record Checks Reform Act, 2015 (ontario.ca/laws/statute/15p30), crjmc.net.