Q&A: BAO Licence renewal fee

Questions and Answers
This Q&A is for the public and professionals licensed by the Bereavement Authority of Ontario (BAO).

The fee is called the Bereavement Authority of Ontario Consumer Protection Fee.

For the public, we hope the information on this page explains our fee for you and your family.
For business operators, who choose to display the fee, you may use this information in answering questions about the fee, as of July 1, 2023.  

About the
Bereavement Authority of Ontario
Consumer Protection Fee

On July 1, 2023, the BAO increased its operator licensing renewal fees to $30 per interment, scattering, cremation, hydrolysis, death registration, including those under social services programs. The licensing renewal fee is called the Bereavement Authority of Ontario Consumer Protection Fee. Responsible for protection of the public interest, the BAO regulates, ensures compliance with the law, and supports licensed professionals across the province. For background about the fee, please read our web post from May 1, 2023.

Top questions

A. What’s the fee for?
The licence renewal fee is charged by the Bereavement Authority of Ontario (BAO) in order to provide its services of information on options in bereavement services and to regulate the bereavement sector profession making sure the law is consistently followed.
The BAO’s regulatory work includes responding to public complaints and questions, inspecting and providing guidance to bereavement businesses and professionals, which it licenses across Ontario to better serve you – the public. The BAO is wholly funded by licensee fees (not tax dollars).
Please read the BAO’s free Consumer Information Guide on the BAO website or in print. A printed copy is available to anyone who wants it at any funeral home or other licensed facility.

B. Is this a new fee?
The fee itself is not new. What is new is that business operators may opt to display the fee on their contracts with consumers. It should be treated like other disbursements on service contracts (burial permit, coroner’s fee).
The vast majority of BAO licensees (individuals and business operators), who took our anonymous survey earlier this year, said that they want to show the fee on their online and printed price lists and on their service contracts with consumers.

C. What is the BAO?
The Bereavement Authority of Ontario is a government delegated authority and not-for-profit corporation administering provisions of the Funeral, Burial and Cremation Services Act, 2002 (FBCSA) on behalf of the Ministry of Public and Business Service Delivery.
Responsible for protection of the public interest, the BAO regulates, ensures compliance with the law, provides resources and services to licensed:

• Funeral establishment operators, directors and preplanners;
• Cemetery, crematorium and alternative disposition operators;
• Transfer service operators; and
• Bereavement sector sales representatives across Ontario.

The BAO is wholly funded by licensee fees (not tax dollars).

Additional questions and answers

Q1. Who pays for the licence renewal fee increase?
The licensing renewal fee increase is paid by the professionals and businesses licensed by the BAO. The fee is part of licensees’ costs of doing business and can be added as a disbursement on consumer contracts and price lists.

Q2. By how much are licence renewal fees increasing?

• For Personal Licensees: The fee increase is 7.6 per cent simply to cover inflation.
• For Business Operators: The fee increase addresses inflation, plus an increase (for operators only) to cover the BAO’s growth obligations related to its strategic plan and Office of the Auditor General of Ontario’s recommendations. The fees are equalized among operator types:
  • Cemeteries, crematoriums and hydrolysis facilities pay $30 total per death (per activity) up from $13.63. This includes per interment, scattering, cremation, hydrolysis, including those under social services programs.
  • Funeral homes and transfer services pay $30 total per registered death (per activity) up from $18.18.

There is also a minimum $300 licensing renewal fee for the funeral homes and transfer services, who have fewer than 10 registered deaths in a year. They are exempt from the $30 per death (per activity) fee.

Q3. When do licensees start paying (and/or charging) the fee?
The Bereavement Authority of Ontario Consumer Protection Fee started July 1, 2023.
Licence renewal fees for bereavement sector businesses are based on their prior 12 months of activity (number of deaths registered, cremations, hydrolysis, scatterings, or interments). All business operators pay a combination of the two fees in the next licence renewal period (November 2023 – March 2024).

Q4. Did the BAO do any analysis about licensee fees?
Yes. We developed and submitted our Fee Review Analysis to the Minister of Public and Business Service Delivery on Dec. 13, 2022. You may read it here.

Q5. Is the exemption for small cemeteries with fewer than 10 interments (burials) still in effect?
Yes, the fewer-than-10-deaths (interments) a year exemption still applies to cemetery operators.

Q6. For the upcoming operator licence renewal period, how will the fees be calculated?
For the 2024 licensing year, the operator licensing renewal fees will be a combination of the existing (old) fee structure and the new fee structure. The existing (old) fees will be applied to activities conducted before July 1, 2023, and the new the $30 fee will be applied to activities conducted from July 1, 2023 onward.
For cemetery, crematorium and hydrolysis operators, the calculation looks like this:
$17.04 + ($13.63 x No. of total activities for period of January 1, 2023 to June 30, 2023) + ($30 x No. of total activities for period of July 1, 2023 to December 31, 2023)
For funeral establishments and transfer services, it looks like this:
$227.20 + ($18.18 X No. of deaths registered for period of Nov 1, 2022 to June 30, 2023) + ($30 X No. of deaths registered for period of July 1, 2023 to Oct 31, 2023).
After this upcoming renewal period, there will no longer be any base fee component to the licence renewal fee.

Q7. Does the licence renewal fee apply to all deaths?
No. There are exceptions. The fee does not apply to deaths not required to be registered, such as products of conception that do not constitute a stillbirth under the Vital Statistics Act, 1990 (fetuses that are less than 500 grams in weight or less than 20 weeks of gestation); likewise, it does not apply to cremation, interment or scattering of products of conception.

Q8. Does the BAO licence renewal fee apply to deaths registered outside of Ontario?
No. The fee applies only to deaths registered in Ontario.

Q9. Will the Harmonized Sales Tax (HST) be subject to – or added to – the licensing fee, called the Bereavement Authority of Ontario Consumer Protection Fee?
The BAO does not charge HST on any licensing renewal fees, or any of its fees, for that matter.
The licensing fee, which we call the Bereavement Authority of Ontario Consumer Protection Fee, will continue to be charged by the BAO to operators without taxes (as in previous years). 

Please note: We’ve revised the BAO’s sample funeral and transfer services contract templates (see the tab on the webpage), which may provide additional information for you. We also have a Sample Cemetery Contract template (see the tab on the webpage), which is not to be used for preneed services and supplies.