Why We’re Requesting Data on Director Approvals

Staff shortages continue to be one of the most pressing challenges in Ontario’s child care sector. Low wages, high workloads, and limited support make it difficult to attract and retain qualified early childhood educators (ECEs). As a result, many child care centres are struggling to meet licensing requirements while maintaining the quality of care that children and families deserve.

One way operators have been managing these gaps is through Director Approvals—a process that allows someone without an RECE designation to temporarily fill a role that would normally require one. While this is meant to provide flexibility during short-term staffing shortages, we are concerned that overreliance on Director Approvals is becoming normalized and may contribute to the deskilling of the workforce and a decline in child care quality.

At present, there is no public data on how often Director Approvals are being used or under what circumstances. That is why B2C2 has submitted a Freedom of Information (FOI) request to the Ministry of Education.

What Is a Director Approval?

Under O. Reg. 137/15, section 54(1) of the Child Care and Early Years Act, licensees can request special approval from the Ministry to employ staff who do not meet the usual qualifications for a role, most commonly substituting non-ECEs in positions that would typically require a registered ECE.

This process was designed as a short-term solution in exceptional cases. However, in the context of chronic staffing shortages, we are concerned it may be used routinely rather than selectively, eroding the long-term capacity of the sector.

What We’re Asking For

Our FOI request asks the Ministry to provide:

• The total number of Director Approvals granted for non-ECEs over the past five years.
• Breakdowns by:
  • Region (by Service System Manager)
  • Auspice type (for-profit, non-profit, public; Montessori vs. non-Montessori)
  • Role type (staff working with children, program directors, support staff)
• Any internal or public-facing criteria used to assess and approve these requests, such as manuals, guidelines, or checklists.

We have also asked that any personal information be removed by FIPPA so that aggregated data can be made available.

Why This Matters

Director Approvals may help centres stay open, but when used excessively, they compromise care quality and weaken the profession. They should be used sparingly, with clear oversight and transparency.

By accessing this data, we aim to understand the scope of this practice and to ensure that it is not replacing investments in sustainable staffing strategies. We want to see a child care system where qualified educators are the norm, not the exception.

This FOI is part of our ongoing work to promote high-quality, equitable, and publicly accountable child care in Ontario—and to advocate for the workforce investments that make that possible.