The Office of the Auditor General of Ontario released the results of its routine performance audit of RPRA in December 2025.
The report made 11 recommendations to strengthen RPRA’s effectiveness. RPRA agrees with the recommendations and has committed to implementing all of them over the next 2-5 years. RPRA will publicly report on its progress in fulfilling each recommendation as part of its commitment to transparency and accountability.
- Recommendation 1 – Address unregistered producer cases
- Recommendation 2 – Finalize verification and audit procedures
- Recommendation 3 – Develop and publish guidance on the buying and selling of recovered resources
- Recommendation 4 – Develop and apply risk-based processes for late reporting by producers
- Recommendation 5 – Establish targets to achieve risk-based outcomes for each stage of the escalation proces
- Recommendation 6 – Establish a formal process to proactively identify and understand potential systemic compliance challenges
- Recommendation 7 – Develop a formal debt management policy
- Recommendation 9 – Evaluate RPRA’s fee setting policy
- Recommendation 10 – Review and revise performance measures
- Recommendation 11 – Develop and apply procedures to periodically verify the completeness and accuracy of collection site information
- Recommendation 12 – Implement necessary systems and processes to meet public reporting targets
Note: Recommendations 8, 13, 14, and 15 were directed to the Ministry of the Environment, Conservation and Parks and are not included on this webpage. Contact the ministry for questions about recommendations directed to the ministry.
Recommendation 1
Address unregistered producer cases
Action # | Action item | Status |
1.1 | Develop a risk-based target for addressing unregistered producer cases that RPRA has deemed low priority. | In progress |
1.2 | Deploy the necessary staff resources to reduce the backlog of potential unregistered producer cases and to meet the developed target. | Completed |
1.3 | Report annually to its Board, the Ministry and the public on its performance against this target. | In progress |
1.4 | Develop and implement options for additional outreach initiatives with supplier industry associations to better identify potential unregistered producers among industry members and raise awareness of the registration requirement. | In progress |
1.5 | Establish and promote a dedicated mechanism, such as a whistle-blower web form, for receiving confidential reports of potential free riders. | In progress |
RPRA’s response |
||
| RPRA will develop risk-based targets for addressing low-priority unregistered producer cases, and deploy necessary resources to reduce the existing low-priority backlog and meet the new targets. RPRA will report annually on performance against the new targets, consistent with the performance reporting it already has in place for high-priority cases. RPRA will also be considering new ways to identify potential unregistered producers, including engaging with industry on additional outreach initiatives as part of its 2026 business plan commitment to develop a new compliance awareness and outreach strategy, and developing a web page for receiving confidential reports of potential free riders. |
||
Recommendation 2
Finalize verification and audit procedures
Action # | Action item | Status |
2.1 | Engage with the appropriate stakeholders, such as auditing firms and PROs, to take steps to finalize the verification and audit procedures for all material programs as soon as possible. | In progress |
2.2 | Once the verification and audit procedures are finalized, implement processes to monitor and enforce the requirement to have performance data verified for all material programs. | In progress |
RPRA’s response |
||
| RPRA will continue its engagement with stakeholders as part of its efforts to finalize the verification and audit procedures for all material programs. Once the procedures are finalized and the Ministry has posted them on the Environmental Registry or in the Ontario Gazette, RPRA will implement risk-based processes to enforce them. At the same time RPRA is finalizing these new procedures, RPRA also plans to review existing verification and audit procedures to improve data quality and reduce burden for registrants, as set out in its 2026 business plan. | ||
Recommendation 3
Develop and publish guidance on the buying and selling of recovered resources
Action # | Action item | Status |
3.1 | Work with all relevant stakeholders to develop and publish guidance on the buying and selling of recovered tonnage in the form of performance credits, across all material programs, including how the materials are to be audited, as soon as possible. | Completed |
RPRA’s response |
||
| Throughout 2025, RPRA engaged with stakeholders to develop and publish guidance on the buying and selling of recovered resources. The guideline was released in November 2025 and is to be applied beginning with the 2026 performance year. More information is available here. | ||
Recommendation 4
Develop and apply risk-based processes for late reporting by producers
Action # | Action item | Status |
4.1 | Develop and apply risk-based processes for following up on automated email notifications for producers that have been identified as non-compliant with reporting requirements. | In progress |
4.2 | Develop and apply risk-based processes and timelines for escalating compliance or enforcement activity where producers fail to adhere to a compliance order and/or administrative penalty issued for non-compliance with reporting requirements within the time provided. | In progress |
RPRA’s response |
||
| RPRA will expand its risk-based processes for late reporting by producers by adding to the established processes and targets it already has in place for high-priority cases. Risk-based timelines and outcomes for following up on automated communications, and escalating compliance or enforcement activity where escalation is appropriate, will also be implemented. | ||
Recommendation 5
Establish targets to achieve risk-based outcomes for each stage of the escalation process
Action # | Action item | Status |
5.1 | Establish targets to achieve risk-based outcomes for each stage of the escalation process. | In progress |
5.2 | Monitor and publicly report on its performance in meeting those targets. | In progress |
RPRA’s response |
||
| RPRA will develop targets to achieve risk-based outcomes for each stage of its escalation process, consistent with its risk-based compliance framework and in line with existing case-handling targets. Once the new targets are in place, RPRA will monitor and publicly report on its performance in meeting them. | ||
Recommendation 6
Establish a formal process to proactively identify and understand potential systemic compliance
Action # | Action item | Status |
6.1 | Establish a formal process to analyze compliance data, trends and input from the stakeholder community to proactively identify and understand any potential systemic compliance challenges. | In progress |
6.2 | Report the results of analyses to MECP to support MECP’s work making evidence-based regulatory decisions. | In progress |
RPRA’s response |
||
| RPRA will establish a formal process to proactively identify and understand potential systemic compliance challenges, incorporating registry data and input from stakeholders. The results of those analyses will be reported to MECP to support its policy work. | ||
Recommendation 7
Develop a formal debt management policy
Action # | Action item | Status |
7.1 | Develop a formal debt management policy that outlines RPRA’s long-term financial objectives, and procedures for borrowing, repaying and monitoring RPRA’s debts. | In progress |
7.2 | As part of these standard borrowing procedures, obtain three or more proposals when pursuing debt financing, to allow for comparison of terms, interest rates, fees and other conditions. | In progress |
7.3 | Once a formal debt management policy has been developed, report to the RPRA Board on its continuing compliance with the policy. | In progress |
RPRA’s response |
||
| RPRA will develop a formal debt management policy that consolidates its existing long-term financial objectives and board-approved financial controls, procedures and limits relating to debt management. The policy will also include new procedures related to obtaining lending proposals and will address board reporting and oversight mechanisms, consistent with RPRA’s current financial compliance and debt management reporting to the board. | ||
Recommendation 9
Evaluate RPRA’s fee setting policy
Action # | Action item | Status |
9.1 | Evaluate RPRA’s fee-setting process to identify options for reducing fee variability and unpredictability for producers, and revise its processes to incorporate any practical options. | In progress |
RPRA’s response |
||
| In October 2025, RPRA launched a review of its cost allocation and fee-setting methodologies to identify practical options for reducing variability and unpredictability. The review is in progress with stakeholder engagement anticipated for early 2027. | ||
Recommendation 10
Review and revise performance measures
Action # | Action item | Status |
10.1 | With input from MECP, review and revise RPRA’s performance measures to be specific, measurable, achievable, relevant, time bound and include measures that more closely monitor and report on RPRA’s operational and financial performance and risks. | In progress |
RPRA’s response |
||
| RPRA will continue reviewing and revising its performance measures to be specific, measurable, achievable, relevant, and time-bound with input from MECP, industry associations and registrants. As RPRA’s producer responsibility programs continue to transition, and as its enforcement, registry service, and public reporting functions continue to mature as part of its 2025-2030 Strategic Plan, new data will be available to help expand the kinds of activities it can report on and measure against. | ||
Recommendation 11
Develop and apply procedures to periodically verify the completeness and accuracy of collection site information
Action # | Action item | Status |
11.1 | Develop and apply procedures to periodically verify the completeness and accuracy of collection site information reported on RPRA’s “Where to Recycle” map, including contacting PROs as needed, and then updating the map to ensure it is complete, accurate and relevant. | In progress |
RPRA’s response |
||
| RPRA will develop and apply procedures to periodically verify the completeness and accuracy of the collection site information required to be reported to it. RPRA has already committed to improving its collection system reporting in its 2026 business plan, including matching reporting processes in the registry with the recent amendments to collection site requirements across most of its programs. Additional compliance procedures will be developed and implemented after this project is complete. | ||
Recommendation 12
Implement necessary systems and processes to meet public reporting targets
Action # | Action item | Status |
12.1 | Implement the necessary systems and processes to meet RPRA’s public reporting targets for all programs. | In progress |
RPRA’s response |
||
| RPRA will implement the necessary systems and processes to meet its public reporting timelines for all programs, consistent with its longer-term strategic goal of improving the scope and accuracy of its public reporting. | ||