Understanding the Impact of Bill 10 on Private Investigators in Ontario

What Ontario’s new drug-related property liability law means for the investigative profession
On June 5, 2025, Ontario’s Bill 10: Protect Ontario Through Safer Streets and Stronger Communities Act received Royal Assent. While much of the early discussion focused on private security, Bill 10 has direct and significant implications for Ontario’s licensed Private Investigators (PIs) as well.
Because the Act places criminal liability directly on landlords and property owners who knowingly allow drug production or trafficking on their premises, many will now rely more heavily on professional investigative services to detect, document, and prevent these activities.
This shift creates new investigative responsibilities, new risks, and new opportunities for Ontario PIs operating under the Private Security and Investigative Services Act (PSISA).
What Bill 10 Actually Does — and Why PIs Should Care
Schedule 8 of Bill 10 targets the production and trafficking of illegal drugs in both commercial and residential spaces.
Penalties include:
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Up to $250,000 in fines for individuals
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Up to $1,000,000 for corporations
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Potential jail time
Landlords can be charged if they knowingly permit illegal drug activity.
But “knowing” can include what a landlord reasonably should have known — which is where private investigators come in.
Landlords, property managers, event venues, and hospitality operators will increasingly require:
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Background investigations
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Due diligence checks on tenants or contractors
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Investigative documentation that can withstand scrutiny in court
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Evidence collection aligned with criminal investigation standards
Bill 10 dramatically raises the standard for what constitutes reasonable measures to prevent drug activity — and PIs will often be the professionals tasked with proving those measures were taken.
Why This Matters for Private Investigators
Private Investigators are uniquely positioned to support clients affected by Bill 10.
Your role may now include:
1. Enhanced Due Diligence for Landlords and Property Managers
PIs may be asked to conduct:
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Tenant background checks
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Corporate due diligence for commercial leasing
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Investigations into chronic nuisance units
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Verification of suspicious activities on properties
2. Evidence-Gathering to Demonstrate “Reasonable Measures”
Since Bill 10 doesn’t clearly define reasonable measures, documentation becomes critical.
PIs may be responsible for:
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Covert observations
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Surveillance logs
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Photographic and video evidence
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Witness interviews
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Pattern-of-activity investigations
3. Support for Event Venues, Nightclubs, and Hospitality Sites
These environments are highlighted in the Bill. Private investigators may be contracted to:
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Conduct internal investigations
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Gather intelligence on drug trafficking patterns
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Identify high-risk staff, contractors, or patrons
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Support management with investigative reporting for police
4. Supporting Security Companies in Compliance
Many security firms will now need:
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Consulting from licensed PIs
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Investigative support for suspected drug activity
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Training in documentation, report writing, and evidence protection
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Third-party investigations when guards observe wrongdoing
You may also find opportunities in policy development, risk assessments, and internal investigations.
Practical Scenarios Illustrating PI Involvement
Scenario 1: Drug Use at a Large Event
Security reports drug activity but lacks clear documentation.
A PI may be engaged to:
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Conduct follow-up interviews
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Review CCTV and confirm timelines
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Provide a detailed investigative report
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Identify systemic risk factors for the client
Scenario 2: Suspected Trafficking in a Rental Unit
A landlord notices unusual activity or receives complaints.
A PI may:
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Conduct surveillance
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Document visitor patterns
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Identify potential trafficking indicators
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Prepare evidence for police or legal counsel
Scenario 3: Staff Involvement in Drug Activity
Event staff or contractors are suspected of drug use or sales.
PIs may:
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Conduct internal workplace investigations
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Collect statements
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Perform digital/social media intelligence gathering
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Provide evidence to support termination or criminal investigation
How Agencies Should Prepare
PI Agencies Should:
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Update service offerings to include Bill-10-focused investigative packages
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Ensure investigators understand drug-related behaviours and trafficking indicators
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Strengthen reporting standards and evidence practices
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Build partnerships with law enforcement and security firms
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Train PIs on legal boundaries, including Trespass to Property Act, PSISA limits, and surveillance laws
Individual Private Investigators Should:
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Upgrade skills in surveillance, documentation, and evidence handling
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Refresh knowledge on drug recognition and behavioural indicators
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Improve communication with landlords, security teams, and police
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Ensure every case file reflects rigorous, court-ready documentation
Conclusion
Bill 10 places unprecedented responsibility on landlords — but it simultaneously increases the demand for skilled Private Investigators to help clients avoid liability through early detection, effective documentation, and professional investigative reporting.
Ontario’s PI industry is now positioned to play a critical role in:
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Identifying drug activity
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Supporting enforcement
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Protecting clients from liability
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Improving community safety
With enhanced training, stronger investigative standards, and proactive service offerings, PIs can help Ontario’s property owners and event operators comply with the new law — while expanding the value and visibility of the PI profession across the province.
