November 21, 2025 Ministry…

November 21, 2025

Ministry of Transportation
5th Floor, 777 Bay Street
Toronto, ON M7A 1Z8

Re: Consultation on Proposed Amendments to the Towing and Storage Safety and Enforcement Act,
2021To Support Setting Select Tow and Vehicle Storage Rates

The Insurance Bureau of Canada (IBC), representing Canada’s property and casualty (P&C) insurers, appreciates the opportunity to provide feedback on the Ontario Ministry of Transportation’s (MTO) proposed amendments to the Towing and Storage Safety and Enforcement Act (TSSEA).

IBC and its members welcome the Ministry’s proposal to directly establish maximum allowable rates for select towing and vehicle storage services. However, we believe that implementing a flat-rate fee schedule would provide even greater benefits by introducing much-needed predictability to a sector that has long been marked by volatility. This approach would strengthen oversight and transparency, promote fairness and, most importantly, enhance safety for Ontario’s drivers. While the Ministry’s approach of setting maximum allowable rates would help bring some consistency to a system currently plagued by wide variations in pricing, a flat-rate fee schedule remains the preferred solution to deliver true clarity and fairness.

While this is a positive development, we recommend that the Ministry provide further clarity on what is meant by “select” towing and storage services. Clear definitions are necessary to ensure consistency and prevent unintended regulatory gaps. This information will help ensure that tow operators and claims processing teams are working from the same understanding when invoicing and paying for towing services.

Tow and Vehicle Storage Rates

In considering what constitutes reasonable rates, IBC recommends using the fee schedule from the Tow Zone Pilot as a baseline. The fee schedule is working effectively, and adopting it would provide consistency and predictability. Using it as a reference point would simplify future reviews when rates are questioned, rather than requiring the government to assess several rate structures for essentially the same service.

Towing

In the interest of avoiding escalating add-on fees, IBC recommends pursuing the concept of a “standard, all-inclusive tow.” This approach reflects historic standard practice and aligns with common practice across Canada.

• Services to be included in the price of a consistent standard tow should include:

o A minimum distance travelled, such as the first 20 kilometres. Afterwards, kilometres should be charged at no higher than $4/km.
o Dollies
o Flat beds
o Cleanup (first 30 minutes)
o On-scene wait time

• In addition, pictures of the tow should be required, along with photos proving the use of other services that are not included in the definition of a standard tow. Failing to include photos or other evidence to prove that a service was delivered should preclude a tow operator from recovering payment.

Recovery

• IBC recommends that recovery-related charges be itemized to promote transparency and consistency across the sector. We reiterate that these charges should align with the structure of the Tow Zone Pilot, which already includes provisions for cleanup and wait time. However, we propose that certain fees be updated to reflect current operational realities (see below). We further recommend the inclusion of winching as a distinctive service category.

• The following rates are proposed for single service charges:

o Winching: $100 maximum
o Wait/standby time at Collision Reporting Centre or lengthy on-scene report: $60/hour up to 4 hours = $240 maximum
 A situation where wait or standby time would be charged could include:
 A driver hits an electrical pole, and the fire department and police need to make the vehicle safe before it can be towed.
 The police require the tow operator to wait until they finish the accident report before allowing the vehicle to be moved.
o Clean up flat-fee range: $50-$120
o Absorbent material: $10 per bag

Storage

• Storage should be charged as a flat, daily rate. A single rate should exist for indoor and outdoor storage; however, should this be deemed unworkable, a minor premium could be added to vehicles stored indoors.

• Fees that should be excluded as unreasonable/illegitimate include:

o Administrative fees
o Release Fees
o Pull Out fees
o Fuel Surcharges
o Gate fees
o Non-drive fees
o Yard cleanup fees
o Jack and block fees
o Forklift fees

Additional Considerations
• IBC recommends that the Ministry establish provincial pricing reviews at a fixed period, such as every 5 years.

Conclusion

In conclusion, IBC is encouraged by the Ministry’s efforts to strengthen oversight and bring consistency and predictability to the towing and storage sector through the proposed amendments. Establishing clear, fair, and predictable rates represents a meaningful step forward in protecting Ontario drivers.

However, while this proposal is a positive development, implementing a flat-rate schedule remains the best option to bring stability to the towing sector. A flat-rate approach would significantly reduce towing-related violence and criminal activity by limiting opportunities for exploitation and conflict. There are well-documented links between violence in the sector and insurance payouts, and a flat-rate schedule would help address these issues, contributing to a safer environment for drivers, insurers, tow operators, and Ontarians as a whole.

Should you have any questions, please do not hesitate to contact me.

Sincerely,

Amanda Dean

CC: The Honourable Robert J. Flack, Minister of Municipal Affairs and Housing