Ontario moves hundreds of thousands of non-emergency patients a year in vehicles that no law regulates, staffed by people no law requires to be trained, by companies that can charge those patients whatever they like.
That is not a rhetorical flourish. It is a description of the current legal position, and every element of it is verifiable in the statute. Here is how it happened, and why fifteen years of promises have not changed it.
How the gap works, in the text of the Act
Ontario's Ambulance Act defines an ambulance in two limbs. The second limb is the one that matters, and it is conjunctive. It captures a conveyance for a person who has been judged to be in an unstable medical condition, and to require the care of a physician, nurse, other health care provider, emergency medical attendant or paramedic while being transported, and to require the use of a stretcher.
All three elements must be present. So consider the most common non-emergency transfer there is: a medically stable patient who needs a stretcher because they cannot sit up, moving from a hospital to a long-term care home.
- They are not in an unstable condition, so the first element fails.
- Therefore the vehicle is not an ambulance.
- Therefore the business is not an ambulance service.
- Therefore the Act's certification requirement never applies to it.
We searched the Act's principal regulation in full. It contains no patient-transfer provision. The gap is not hidden in a subsection. It is simply empty space.
What that means in practice
- No vehicle standard. Nothing specifies what the vehicle must be, how it must be equipped, or how it must be maintained.
- No staffing standard. Ontario requires no credential of any kind for staff on a non-ambulance transfer. Not a personal support worker certificate, not emergency medical responder training, not first aid. The only constraint is a prohibition on holding yourself out as a paramedic.
- No patient care standard and no oversight body. Nobody inspects, licenses or audits.
- No fee protection. The Act's fee restrictions attach only to certified ambulance services. An unregulated transfer company may bill the patient whatever it likes, and patients being discharged from hospital are rarely in a position to negotiate.
Municipal licensing does not fill the gap. We extracted Toronto's licensing chapter and its vehicle-for-hire chapter in full, 478 pages between them. They contain zero occurrences of ambulance, stretcher, patient transfer, medical transport, wheelchair or paramedic. Toronto's private transportation company definition is broad enough on its face to reach a pre-booked operator, and no exemption resolves the ambiguity, but nothing in the city's rules addresses patient safety. Ottawa's by-law has an auxiliary services category for prearranged transport with personal assistance that appears to capture this work, which makes it the closest municipal fit we found in the province.
The Ombudsman found this in 2011
On June 10, 2011, the Ontario Ombudsman announced findings from an investigation into an industry that, in his office's words, "handles non-emergency transportation of hundreds of thousands of patients every year."
The finding was blunt: "Our investigation uncovered serious issues, from a lack of infection control to unsafe vehicles and poorly trained staff."
The response looked like a resolution. The Ministries of Transportation and Health "pledged to implement the Ombudsman's recommendation that the medical transportation services industry be regulated," and announced that legislation would be introduced "at the earliest opportunity." Because the government committed, no formal report was ever published. The matter was closed on the strength of a promise.
We checked whether the promise was kept
This is the part nobody seems to have done, so we did it.
We parsed the Legislative Assembly of Ontario's bill listings across the 37th through 44th Parliaments, covering 3,472 bill rows from 1999 to June 2026. We searched for every bill matching ambulance, paramedic and transfer keywords.
Six bills matched those keywords. Not one of them regulates non-emergency patient transfer services.
Fifteen years after two ministries told the Ombudsman that legislation would be introduced at the earliest opportunity, no such bill has ever been introduced. Not tabled and defeated. Not introduced and left to die on the order paper. Never introduced at all.
A correction to something you may have read
We went looking for a coroner's inquest on this, because it is the kind of gap that usually produces one, and because we had assumed one existed.
We searched three independent primary corpora: Ontario's open data coroner's inquest recommendations dataset covering 3,165 recommendation rows from 2018 to 2024, the annual verdict pages published on ontario.ca from 2020 to 2026, and 186 archived individual verdict pages from the retired Chief Coroner site covering roughly 2015 to 2021.
There is no Ontario inquest verdict recommending regulation of private patient transfer services in any of them. We can verify that negative for 2015 through 2026. Pre-2015 verdicts were never migrated and the master index is unretrievable, so we cannot speak to that period.
If you see an article asserting that a coroner's inquest called for regulation, ask for the citation. The Ombudsman finding is real, better sourced, and does the same work.
Why this matters if you operate here
Two things follow, and they pull in opposite directions.
Entry is easy. There is no licence to obtain, no inspection to pass and no credential to earn. You can start operating in Ontario faster than in any other province in this series. Manitoba, by contrast, requires a licence with a public need test and a mandatory agreement with the provincial health organization.
And that is exactly the problem. A market with no floor is a market where the cheapest operator sets the price, and where a hospital discharge planner has no way to distinguish a serious business from a van with a stretcher in it. The Ombudsman's findings describe what that produces.
The commercial implication is straightforward. In an unregulated market, the standards you adopt voluntarily are your differentiation. Insurance limits well above the province's $200,000 minimum. Documented driver training and criminal record checks that no regulation requires. Vehicle inspection and maintenance records. Infection control protocols you can actually show someone. Hospitals, insurers and families notice which operators hold themselves to a standard nobody enforces, because they have been burned by ones that do not.
One compliance item does bite, and operators miss it constantly. Ontario's Regulation 611 defines an accessible vehicle as one designed or modified to transport persons with disabilities and operated for compensation, and accessible vehicles require a six-month inspection sticker. This applies even to a sub-ten-seat van that falls outside commercial driver licensing and outside the commercial vehicle operator registration system. There is almost no regulation in this space, and this is one of the few pieces that is real.
Sources
Ambulance Act R.S.O. 1990 c. A.19 and O. Reg. 257/00. R.R.O. 1990 Reg. 611. Ontario Ombudsman, non-emergency medical transportation services investigation, June 10, 2011. Legislative Assembly of Ontario bill listings, 37th to 44th Parliaments. Ontario coroner's inquest recommendations open dataset. Toronto Municipal Code Chapters 545 and 546.
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