PRODUCT MAP · LEGAL STATUS ≠ ECONOMIC OUTCOME
What changes at the product level, and what still needs proof.
Use the audited product map to separate statutory scope, proposed compensation disclosure, unresolved classification and product-term questions before modelling any economic effect.
01
THE QUESTIONS THAT MATTER BEFORE THE TABLE
Product classification is only the first layer.
The public record needs to distinguish legal scope, product terms, customer behaviour and channel substitution.
The proposed 30% line is a disclosure test, not a compensation cap.
The economic question is behavioural: what happens after disclosure? The proposed rule itself does not require a dealer to reprice a product to 30% or below.
Do not invent a one-year B.C. coverage rule.
No reviewed B.C. enactment or proposed Council rule in the current evidence record requires creditor life, disability or Critical Health coverage to move to one-year terms or annual re-enrolment. Any future change must be traced to the exact rule, policy or insurer contract.
Warranty and protection products still require product-specific analysis.
Appearance, glass, theft, tire, key, repair and similar products can turn on seller class, product wording, insurer, obligor and distribution structure. Brand alone is not the legal test.
Equivalent products may move through different channels.
The research programme should test whether business migrates among dealer, OEM-affiliated, insurer, lender or other channels rather than assuming a reduction in one channel becomes consumer savings.
02
AUDITED PRODUCT STATE
Read the row before modelling the compensation rule.
Each row retains its evidence state and model boundary. An unresolved classification does not become a forecast.
One sale. Three legal moments.
Follow each product or distribution structure from today, through the enacted January 1 framework, into the still-proposed compensation rule. Open a row for its full position and sources.
Enacted · Jan 1, 2027 Proposed · No effective date Model · Not a forecast
Vehicle warranty insuranceEVIDENCE STATE · PROPOSEDCheck the current exemption and enacted transition.
- CURRENT B.C. POSITION
- An unlicensed motor vehicle dealer may currently rely on the specific exemption for vehicle warranty insurance sold incidentally to its ordinary business.
- ENACTED · JAN 1, 2027
- The enacted RIA regulation names vehicle warranty insurance for motor vehicle dealers, changes the existing dealer exemption, and provides a limited transition for eligible activity.
- PROPOSED · NO EFFECTIVE DATE
- Proposed Rule 7(25)(g) would require the full qualifying compensation amount in writing when compensation is more than 30% of the client product price. It is proposed and has no effective date.
- MODEL · NOT A FORECAST
- A disclosure scenario estimates behaviour only after dealer-entered price and compensation inputs. It does not predict take-up, claims, or store survival.
4 primary sources
Guaranteed asset protection insurance (GAP)EVIDENCE STATE · PROPOSEDStart with the existing licensed distribution path.
- CURRENT B.C. POSITION
- GAP is already insurance in B.C. A licensed insurance agent or salesperson may offer it. The Council says an unlicensed dealership may offer vehicle warranty only, so GAP already requires an appropriately licensed distribution path.
- ENACTED · JAN 1, 2027
- The enacted RIA regulation includes GAP within the insurance classes a motor-vehicle-dealer RIA licence may cover. GAP was already insurance, and existing licensed distribution paths remain.
- PROPOSED · NO EFFECTIVE DATE
- Proposed Rule 7(25)(g) would require the full qualifying compensation amount in writing when compensation is more than 30% of the client product price. It is proposed and has no effective date.
- MODEL · NOT A FORECAST
- Any economic output must start with the store’s actual licensed channel, contracts, volume, compensation, cancellations, and claims. No default loss rate is a forecast.
4 primary sources
Credit protection insuranceEVIDENCE STATE · PROPOSEDProduct labels alone do not establish classification.
- CURRENT B.C. POSITION
- Current B.C. exemptions may reach specified incidental credit-insurance activity. The applicable actor, credit arrangement, product wording, and conditions determine the current path.
- ENACTED · JAN 1, 2027
- The enacted RIA regulation names credit protection insurance for motor vehicle dealers and other prescribed business classes, subject to its licence conditions and transition rules.
- PROPOSED · NO EFFECTIVE DATE
- Proposed Rule 7(25)(g) would require the full qualifying compensation amount in writing when compensation is more than 30% of the client product price. It is proposed and has no effective date.
- MODEL · NOT A FORECAST
- Product family: Creditor life · disability · Critical Health (critical illness) · job-loss coverage. Those labels do not establish classification. Check the creditor, payee and income-impairment conditions against the actual contract; death-benefit coverage requires specific confirmation. Any availability or take-up change remains a scenario.
3 primary sources
Service-only etching or trackingEVIDENCE STATE · UNKNOWNCheck the service contract and any payment promise.
- CURRENT B.C. POSITION
- A service-only etching or tracking contract with no payment or indemnity promise is a different structure from theft insurance. The reviewed B.C. sources do not classify every such service contract.
- ENACTED · JAN 1, 2027
- The enacted RIA table names insurance classes, not etching or tracking services as product names. Classification still turns on what the contract promises, not the label on the menu.
- PROPOSED · NO EFFECTIVE DATE
- Proposed Rule 7(25)(g) concerns an insurance product sold by a licensee. Whether it reaches this row depends first on whether the actual contract is insurance.
- MODEL · NOT A FORECAST
- No insurance, licensing, or revenue consequence is assigned without the actual service contract and payment promise. Product naming alone is insufficient.
2 primary sources
Payment-backed theft protectionEVIDENCE STATE · UNKNOWNBCFSA’s stated view; contract classification remains unresolved.
- CURRENT B.C. POSITION
- The BCFSA position is that a promise to indemnify loss on theft is automobile insurance. The B.C. Supreme Court recorded that BCFSA had expressed an opinion, not a binding determination, and held that the statement has no mandatory effect.
- ENACTED · JAN 1, 2027
- A motor-vehicle-dealer RIA licence does not list automobile insurance among its authorized classes. The unresolved contract classification therefore remains material after January 1.
- PROPOSED · NO EFFECTIVE DATE
- The proposed compensation rule does not create missing product authority. The actual classification and licence path must be resolved before disclosure economics are modelled.
- MODEL · NOT A FORECAST
- No B.C. sales-loss assumption follows from BCFSA’s stated position alone. Contract wording, regulator action, and a lawful distribution path remain required inputs.
ALBERTA COMPARATOR · NOT B.C. LAW
Alberta expressly classifies payment-backed theft-deterrent and related ancillary protection products as insurance and added a restricted business licence path for that structure.
4 primary sources
Manufacturer as its own warranty obligorEVIDENCE STATE · UNKNOWNCheck who provides the warranty; no blanket OEM exemption.
About this structure
- CURRENT B.C. POSITION
- There is no blanket OEM exemption. Current section 4 may exempt a qualifying manufacturer, retailer, or specified affiliate from the insurer business-authorization rule for an incidental warranty it provides itself.
- ENACTED · JAN 1, 2027
- The linked amendment narrows that section 4 treatment for named manufacturers, dealers, and affiliates when they act or offer to act as an insurance agent through employees or agents.
- PROPOSED · NO EFFECTIVE DATE
- There is no blanket OEM exemption in the proposed compensation rule. Whether the rule applies depends on the licensed seller, insurance product, price, compensation, and transaction structure.
- MODEL · NOT A FORECAST
- Contract terms, obligor, insurer, agency role, compensation flow, and licence status must be checked. The row is not a forecast of sales, take-up, price, or closure.
4 primary sources
OEM-branded insurer product sold through a dealerEVIDENCE STATE · UNKNOWNCheck the insurer and seller; no blanket OEM exemption.
About this structure
- CURRENT B.C. POSITION
- There is no blanket OEM exemption. A factory name does not replace the current legal tests for the insurer, agent, salesperson, dealership, product class, and applicable exemption.
- ENACTED · JAN 1, 2027
- There is no blanket OEM exemption in the enacted dealer class. If the dealer acts as agent for a prescribed insurance class, the licence and structure-specific rules govern regardless of branding.
- PROPOSED · NO EFFECTIVE DATE
- There is no blanket OEM exemption. Proposed Rule 7(25)(g) would require the full qualifying compensation amount in writing when compensation is more than 30% of the client product price. It is proposed and has no effective date.
- MODEL · NOT A FORECAST
- Contract terms, obligor, insurer, agency role, compensation flow, and licence status must be checked. The row is not a forecast of sales, take-up, price, or closure.
4 primary sources
Non-OEM third-party insurer productEVIDENCE STATE · UNKNOWNCheck the actual product, insurer, seller and contract.
- CURRENT B.C. POSITION
- There is no blanket OEM exemption and no automatic independent-dealer rule. Current treatment depends on the insurance class, insurer, seller, licence, exemption, and actual contract.
- ENACTED · JAN 1, 2027
- There is no blanket OEM exemption in the enacted regime. A motor vehicle dealer acting as agent for a named class follows the RIA path whether the product is factory-branded or independent.
- PROPOSED · NO EFFECTIVE DATE
- There is no blanket OEM exemption in proposed Rule 7(25)(g). The same qualifying-compensation test is written for the licensee, not for a brand category.
- MODEL · NOT A FORECAST
- Contract terms, obligor, insurer, agency role, compensation flow, and licence status must be checked. The row is not a forecast of sales, take-up, price, or closure.
4 primary sources
Captive or affiliated provider structureEVIDENCE STATE · UNKNOWNMap the parties and compensation; no blanket OEM exemption.
About this structure
- CURRENT B.C. POSITION
- There is no blanket OEM exemption. Corporate affiliation alone does not answer whether an entity is insurer, obligor, agent, retailer, or an affiliate within a specific exemption.
- ENACTED · JAN 1, 2027
- There is no blanket OEM exemption for a captive structure. The linked amendment expressly addresses specified affiliates and subsidiaries when acting or offering to act as an insurance agent.
- PROPOSED · NO EFFECTIVE DATE
- There is no blanket OEM exemption in the draft. The compensation flow among captive, dealer, representative, and any other licensee must be mapped against the proposed text.
- MODEL · NOT A FORECAST
- Contract terms, obligor, insurer, agency role, compensation flow, and licence status must be checked. The row is not a forecast of sales, take-up, price, or closure.
4 primary sources
Referral-only structureEVIDENCE STATE · UNKNOWNCheck the actual conduct, compensation, documents and parties.
- CURRENT B.C. POSITION
- There is no blanket OEM exemption. Whether a referral becomes acting or offering to act as an insurance agent depends on the actual conduct, compensation, documents, and parties.
- ENACTED · JAN 1, 2027
- There is no blanket OEM exemption for referrals. The enacted RIA regime does not publish a contract-by-contract safe-harbour decision tree for referral conduct.
- PROPOSED · NO EFFECTIVE DATE
- There is no blanket OEM exemption in the proposed rule. Its application depends on whether the participant is a licensee receiving qualifying compensation as a result of the sale.
- MODEL · NOT A FORECAST
- Contract terms, obligor, insurer, agency role, compensation flow, and licence status must be checked. The row is not a forecast of sales, take-up, price, or closure.
3 primary sources
03
YOUR MENU, LINE BY LINE
15 products and structures on your menu. 3 classes are named. The rest turn on the contract.
The reviewed B.C. sources leave product-specific questions unresolved. These rows distinguish a class expressly listed in the regulation, BCFSA’s stated classification, and matters not resolved in the sources reviewed. Product wording and the seller’s actual authority still require verification.
3 things on your menu are clearly covered by the new licence. 4 sit in a class BCFSA puts in automobile insurance, which item 10 reaches only through GAP and only for a financing shortfall. BCFSA classified those products, it did not say you cannot sell them, and in 2025 the court held its Regulatory Statement has no mandatory effect of its own. What restricts you is the Financial Institutions Act. The other 8 are genuinely unresolved, and none of this waits for January 1, because the classification question has been open since 2024.
Extended warranty, mechanical breakdown
Repairs when something breaks
PRESCRIBED DEALER CLASS
Licensed. This is one of your three.
Vehicle warranty insurance is a defined class, and B.C. confines it to loss or damage "arising from mechanical failure". The definition also expressly excludes anything "included in or incidental to automobile insurance".
Source ↗GAP, guaranteed asset protection
The shortfall if the car is written off or stolen
PRESCRIBED DEALER CLASS
Already insurance. The 2027 RIA licence adds a restricted dealer path.
GAP is already insurance in B.C. The Council says a licensed insurance agent or salesperson may offer it, while an unlicensed dealership may offer vehicle warranty only. The 2027 regulation names GAP within the classes a motor-vehicle-dealer RIA licence may cover.
Source ↗Creditor disability · Critical Health (critical illness) · job-loss coverage
Your loan payments if you cannot work
PRESCRIBED DEALER CLASS
Credit protection is a listed class; the contract must meet its definition.
The regulation defines credit protection insurance as insurance "effected by a creditor" paying the creditor, triggered by "an impairment or potential impairment in an individual's income or ability to earn an income". Loss of income is squarely inside it.
Source ↗Credit life, the one that pays on death
Clears the loan if the borrower dies
NOBODY HAS SAID
The reviewed sources do not expressly resolve death-benefit coverage.
The enacted definition requires creditor-effected insurance paying the creditor on specified income-impairment conditions. It does not expressly mention death in that definition. The sources reviewed for this page do not resolve the classification of a particular death-benefit contract. This is not a finding that creditor life is excluded; obtain product-specific confirmation.
Source ↗Tire and rim
A replacement tire after road damage
BCFSA SAYS OUTSIDE
On BCFSA’s reading, your licence does not reach it.
BCFSA places damage to "the glass, paint, or other part of a motor vehicle" from a fortuitous event in AUTOMOBILE insurance. Item 10 gives a dealer credit protection, GAP and vehicle warranty. GAP is the only one of those the regulation lets sit in the automobile class, and it is confined to the financing shortfall after an unrecovered theft or a total loss, so nothing in item 10 reaches damage to a tire. The 2025 LGM judgment held the Statement has no mandatory effect of its own, but it was about appearance products and made no finding on tire and rim, so this is BCFSA’s stated view rather than a decided question.
Alberta reached the same result explicitly, classifying non-manufacturer tire and rim products as automobile insurance in its October 2025 definitions.Source ↗Windshield and glass protection
Chip repair or a new windshield
BCFSA SAYS OUTSIDE
On BCFSA’s reading, your licence does not reach it.
Glass is named. BCFSA puts damage to the glass of a motor vehicle from a fortuitous event in automobile insurance, which is not a class item 10 grants a dealer.
Alberta names it too: "Automobile insurance that promises to pay some or all of the cost of a windshield replacement relating to glass protection products".Source ↗Service-only etching and tracking
A physical marking or tracking service with no payment promise
NOBODY HAS SAID
Do not silently call a service contract insurance.
BCFSA addresses indemnification for theft or fortuitous damage. A service-only contract with no payment or indemnity promise is a different structure, and no reviewed B.C. source classifies every etching or tracking service.
Alberta’s express classification addresses payment-backed theft-deterrent products. That comparator is not B.C. law and does not silently convert a service-only contract into insurance.Source ↗Payment-backed anti-theft, etching, tracking and converter protection
A payment if the vehicle or a part is stolen
BCFSA SAYS OUTSIDE
On BCFSA’s reading, your licence does not reach it.
Theft is named. BCFSA’s position puts "indemnification for loss in the event of a theft" in automobile insurance. Item 10 does give a dealer GAP, but only for the financing shortfall left after an unrecovered theft, not for the value of the vehicle itself. The 2025 LGM judgment held the Statement has no mandatory effect of its own, and it made no finding on theft products, so the contract wording and the lawful distribution path still decide this.
ALBERTA COMPARATOR · NOT B.C. LAW: Alberta expressly classifies payment-backed theft-deterrent products and created a restricted business licence path.Source ↗Paint, fabric and appearance protection
Repair of paint or interior damage
BCFSA SAYS OUTSIDE
If it pays out on damage, BCFSA says your licence does not reach it.
BCFSA’s stated position places indemnification for fortuitous paint damage within automobile insurance. This is the one row the 2025 LGM judgment is directly about. The court recorded at para. 66 that BCFSA "has not made a determination" on appearance protection contracts and had only "expressed its opinion", and held the Statement has no mandatory effect of its own. The reviewed B.C. sources do not resolve a service-only coating contract with a workmanship guarantee.
Alberta has not addressed paint, fabric, appearance protection or rustproofing in any source read for this page.Source ↗Dent and ding, paintless dent repair
Removal of minor dents
NOBODY HAS SAID
No product-specific B.C. determination was located in the reviewed sources.
Applying BCFSA’s wording to fortuitous dent damage suggests automobile-insurance treatment, but that is an inference. No product-specific B.C. determination was located in the sources reviewed for this page. Alberta classifications and law-firm commentary do not determine B.C. treatment.
Source ↗Key and key fob replacement
A new key if yours is lost or stolen
NOBODY HAS SAID
No B.C. determination was located in the reviewed sources. Alberta is a comparator.
No B.C. regulator has classified key replacement. It is not vehicle warranty, because nothing has mechanically failed, so it must fall in some other class or none.
Alberta puts it in a class of its own: "Property insurance that provides key fob replacement coverage". Property insurance is not a class item 10 grants a B.C. dealer either.Source ↗Rust and corrosion protection
Repair of rust perforation
NOBODY HAS SAID
No applicable classification was located in the sources reviewed for this page.
Rust is neither a sudden fortuitous event nor a mechanical failure, so it sits outside both of the definitions B.C. has published. No B.C. or Alberta source read for this page addresses it. That is the whole answer available today.
Source ↗Prepaid maintenance
Scheduled oil changes and servicing
NOBODY HAS SAID
Classification unresolved in the B.C. sources reviewed for this page.
Nothing is indemnified and no risk is transferred; the customer is prepaying for services. That reasoning is sound but it is reasoning, not a B.C. ruling, and B.C. has published no product list.
Alberta says plans limited to planned maintenance, routine service or minor wear-and-tear repairs may be offered without an insurance licence.Source ↗Roadside assistance sold on its own
A tow, a boost, a tire change
NOBODY HAS SAID
Classification unresolved in the B.C. sources reviewed for this page.
Towing appears inside the vehicle warranty class when it follows a mechanical failure. Sold as a standalone service plan it is not obviously insurance at all. No B.C. source resolves it.
Alberta treats standalone roadside plans as outside insurance licensing.Source ↗Lease excess wear and tear
Your lease-end damage bill
NOBODY HAS SAID
No applicable classification was located in the sources reviewed for this page.
It indemnifies a defined future financial loss, which is the shape of insurance, but it is not mechanical failure and it is not one of the three classes in item 10. Nothing published in B.C. or Alberta addresses it.
Source ↗HOW TO READ THIS IN-SCOPE identifies a prescribed class expressly listed in item 10, subject to the actual product definition and licence conditions. OUTSIDE identifies BCFSA’s stated reading; the court held that the Regulatory Statement has no mandatory effect of its own and recorded no formal determination on the products in issue. UNANSWERED means no applicable answer was located in the B.C. sources reviewed for this page, not that no answer exists anywhere.
04
THIS STARTED IN 2024, AND IT IS NOT SETTLED
A regulator moved the line, a court declined to rule on it, and the question is still open
On April 25, 2024 BCFSA issued Regulatory Statement 24-008, repealing a bulletin that had stood since 2006. It says vehicle warranty insurance reaches loss or damage "arising from mechanical failure", while automobile insurance covers loss "in the event of a theft, motor vehicle accident, or if the glass, paint, or other part of a motor vehicle is otherwise damaged due to a fortuitous event".
Item 10 gives a dealer credit protection, GAP and vehicle warranty. It does not give automobile insurance. So on BCFSA's reading, a product that pays out when a tire, a windshield or the paint is damaged sits in a class the dealer licence does not reach, and the Statement came with no transition period.
A provider took it to court. In LGM Financial Services Inc. v. British Columbia Financial Services Authority, 2025 BCSC 2423, decided December 8, 2025, Justice Majawa dismissed the petition, but read what it actually turned on. The court concluded the Statement "is not an exercise of a statutory power because it does not materially alter the definition of automobile insurance found in the FIA and because it does not have mandatory effect". It did not decide whether these products are insurance.
At paragraph 66 the court recorded this: "BCFSA has not made a determination as to whether the Appearance Protection Service Contracts are automobile insurance. What has happened is that BCFSA has expressed its opinion". So the classification of tire, glass, paint and theft products is the regulator's stated view, not a decided question, and not something the Statement itself makes binding.
The exposure is real regardless. Section 75 of the Financial Institutions Act is what prohibits carrying on insurance business without authorisation, and it applies whatever a Regulatory Statement does or does not do. Manufacturers and at least one provider signed voluntary compliance agreements rather than test it. A dealer relying on the court having "won" the point has misread the judgment.
So January 1, 2027 is the second step, not the first. 2024 raised the question of which products a dealer may sell at all, and it is still open. The 2027 licence decides who at the dealership may sell the ones that are not in doubt, and the proposed rule decides what they must write on the customer's copy.
- BC Financial Services Authority, Regulatory Statement 24-008, Product Warranty, Vehicle Warranty, and Automobile Insurance · Background Information, paragraphs 1 to 3. Dated April 25, 2024 · accessed 2026-09-02
- LGM Financial Services Inc. v. British Columbia Financial Services Authority, 2025 BCSC 2423 (Majawa J.) · Paras. 46 to 49 on mandatory effect, para. 66 on the absence of a determination, paras. 71 to 72 disposition. Judgment December 8, 2025; heard September 10 to 11, 2025 · accessed 2026-09-03
- Financial Institutions Act, RSBC 1996 c. 141, s. 75 · Prohibition on carrying on insurance business without authorization · accessed 2026-09-02
NEXT WORKSPACE
Classification tells you what to review. Store data tells you what is economically exposed.
Use actual product price, provider cost, compensation and penetration inputs. Keep every result labelled as a scenario until observed post-implementation data exist.