Every Ontario brokerage must now send RECO, the provincial real estate regulator, a yearly report on its money: what it owns, what it owes, what it earned, and what it holds in trust. Your broker of record signs it. The first one is due October 30, 2026.
In this issue:
- What RECO asks for
- What the broker of record signs
- The dates that matter now
- Who files, and who does not
- What happens if a filing is late
- Two things that take the longest to prepare
- Before the broker of record signs
What RECO asks for
- From the balance sheet (what the brokerage owns and owes): cash, total current assets, total assets, shareholder’s loans, related third-party loans, total current liabilities, total liabilities and total equity.
- From the income statement (what it earned and spent): total revenue, gross profit, total expenses and net income.
Every figure comes from the brokerage’s own records for the fiscal year.
The filing also asks about money held in trust: what the brokerage holds for others, what it owes from that money, and any trust money no one has claimed. It is filed online through RECO’s MyWeb portal.
What the broker of record signs
The broker of record is the person responsible for the brokerage under RECO. They attest the filing is accurate. They also answer yes or no to a list of statements. In plain words, these include:
- The trust accounts held enough to cover what the brokerage owed from them.
- Trust money was kept apart from the brokerage’s own money.
- A trust reconciliation was done for every month end, and the broker of record reviewed and signed each one.
- RECO was told immediately of any shortfall in the trust account, and the shortfall was covered.
- RECO was told promptly if the brokerage could not pay its bills as they came due, or if its debts were more than its assets could be sold for.
Most of these were already rules. What is new is signing them once a year, in one place, next to the numbers.
The last one changes what the statements are for. They used to show what the brokerage earned. Now they also show whether it can pay what it owes.
The dates that matter now
The last one changes what the statements are for. They used to show what the brokerage earned. Now they also show whether it can pay what it owes.
The dates that matter now
The 90-day window is the change to plan for. From now on, the year-end numbers have to be ready within three months of year end, every year.
Who files, and who does not
- Every Ontario brokerage files. RECO counts about 3,800.
- A brokerage with no trade or trust activity in the year files a shorter version. It declares no trade activity and uploads its trust account statement.
- Agents and personal real estate corporations (PRECs) do not file. If you lead a team inside a brokerage, the filing belongs to your brokerage’s broker of record.
What happens if a filing is late
RECO has set out the steps:
- A $300 late filing fee.
- Referral to RECO’s Discipline Committee.
- A possible further fine of $2,500 and a $1,500 costs award.
- Names of registrants in discipline proceedings can be posted publicly.
- Suspension of registration, refusal to renew it and, in the end, revocation.
Paying the fee does not remove the duty to file. RECO can also require a financial statement certified by a licensed public accountant.
Two things that take the longest to prepare
1. Twelve signed reconciliations. Reconciliations that were usually done are not enough. The broker of record attests that one was prepared for every month end in the fiscal year, and that they reviewed and signed each one. For most brokerages, that is 12 reconciliations and 12 signatures, on file and easy to find.
2. Trust interest the brokerage kept. The filing asks for interest on trust money that the brokerage retained. The word matters. Some of that interest may not be the brokerage’s to keep. It depends on the deposit terms. If interest that belongs to a buyer was booked as brokerage revenue, three things are wrong at once:
- Revenue is too high.
- Trust liabilities are too low.
- Unclaimed trust money is missed.
Before the broker of record signs
- Are shareholder loans and related third-party loans on separate lines?
- Has the broker of record read what the brokerage owns and owes, not just the tax return?
- Do the statements show the brokerage can pay its bills as they come due?
- Is there a signed trust reconciliation for every month end in the year?
- Is any unclaimed trust money listed? Is any trust interest the brokerage kept allowed by the deposit terms?
Do you need a CPA to file?
No. RECO does not require one. It does recommend that an accountant prepare the brokerage’s financial statements. Questions about a specific filing go to RECO at aff@reco.on.ca.
If your fiscal year ended between August 1, 2025 and July 31, 2026, this filing is due October 30, 2026. I put the full detail in a 12-page readiness note, with a checklist you can work through and sign off:
RECO Filing Checklist l Concept Accounting
Preparation can be delegated. The attestation cannot.
If you want to see what this looks like in your own numbers, we can set up an intro meeting.
Build for what you keep, not what you close.
Hashim Awad, CPA
Concept Accounting & Advisory Professional Corporation | conceptaccounting.ca