Ontario's STAR Act: What Performers, Creators & Talent Agencies Need to Know
TORONTO, ON –
Ontario wants to cap talent agency commissions and strengthen pay protections for performers, but that only solves half the problem
The Ontario Government has tabled Bill 105, which includes a new Strengthening Talent Agency Regulation (STAR) Act, which is set to introduce real guardrails around how talent agencies handle performers’ money.
If passed, the Act would, for the first time ever, create a dedicated statute regulating talent agencies that handle payments for entertainment workers such as actors, models, musicians, and other gig economy performers in Ontario. But it won’t replace the need for independent, lawyer-led representation for artists, creators, and talent.
Why Ontario Wants to Regulate Talent Agencies
For years, Ontario’s creative industries—film, TV, commercial work, live performance, and digital content—have operated with virtually no sector‑specific rules governing the relationship between talent agents and artists, or how talent agencies handle performers’ money.
Ontario’s arts and creative industries generate more than $26 billion annually and support tens of thousands of jobs, yet the agencies that sit between performers and their paycheques are completely unregulated.
The STAR Act has been introduced after sustained pressure from unions and support groups, including Alliance of Canadian Cinema, Television and Radio Artists (ACTRA) and the Talent Agents and Managers Association of Canada (TAMAC).
As a concrete example of talent agency misconduct, Compass Artist Management Inc. left more than 60 performers owed over 1 million dollars in unpaid earnings, with no clear timelines or safeguards to ensure talent got paid. The STAR Act targets exactly the kind of payment failure, money-handling risk, and lack of oversight that left performers exposed by a talent agency they trusted.
This case also serves as a reminder that a trade group or agency directory is not the same thing as meaningful worker protection, transparent trust accounting, objective regulatory standards, or enforceable legal safeguards. TAMAC and similar organizations can provide networking, resources, and practical guidance for agencies. But they do not impose binding fiduciary duties on agents, hold agency money in regulated trust accounts, or guarantee that performers will be paid on time.
Those kinds of protections come from legislation like the proposed STAR Act, and from the independent legal advisors who insist that performers’ rights are contractually locked in—terms, payment timelines, and dispute mechanisms—before a single dollar changes hands. If you’re an actor, model, creator or agency owner, the technical details matter.
What the STAR Act Actually Does
The STAR Act is focused on regulating talent agencies and protecting performers’ earnings.
At a high level, the Act would:
Define who is a “talent agency” and who is an “entertainment worker,” and confirm that rights under the Act cannot be waived in a contract between an agent and the talent.
Treat related or associated companies as a single talent agency where appropriate, so an agency cannot easily sidestep the rules by splitting itself into multiple entities.
Prohibit most fees charged to performers, cap commissions, and regulate how performers’ money is held and paid out.
Commission rates among talent agencies have been increasingly pushed far above industry norms, reaching up to 30% in some cases, particularly for vulnerable or emerging performers with less industry experience or access to historical information. The Act would help combat this by establishing a maximum commission rate that agencies are allowed to charge.
As of late April 2026, the bill is at second reading in the Legislative Assembly, meaning the STAR Act is still proposed legislation and not yet in force. If and when the Act becomes law, I’ll set out in detail the important protections it provides for performers and entertainment workers.
What This Means for Talent Agencies
For legitimate, ethical talent agencies, the STAR Act will likely formalize good practices they’re already observing: consistent commissions and strict caps, clear statements, and timely payment of performers.
But for most agencies, the Act will trigger a major operational reset:
Fee structures will need to be reviewed and likely rewritten. Pay‑to‑play models and layered administrative fees will be under scrutiny.
Accounting systems will need to support dedicated accounts and strict reconciliation of client payments, commissions, and remittances to performers.
Compliance risk will become real: inspections, orders, administrative penalties, and even prosecution for repeat or egregious misconduct.
Agency owners and directors should understand that the Act includes director‑level liability for certain unpaid amounts and contraventions, particularly where agencies are insolvent or fail to pay entertainment workers what is owed.
What Artists and Performers Should Be Doing Now
Until Bill 105 passes and comes into effect, your current rights still come from your contracts, existing employment standards legislation, and general civil remedies.
That said, this is the right moment to get ahead of the curve:
Audit your current contracts. Look at what your agency is allowed to charge you (fees, commissions, admin or marketing charges) and how long they can hold your money in their account before paying you.
Track your payments. Keep your own records of what clients paid, what you were promised, and when money actually arrived. This will matter if you need to rely on new complaint mechanisms later.
Ask your agency the hard questions. Do they already use a separate trust account, or is your pay being used to float your agent’s business operations before you get paid? What is the exact commission rate, and how do they justify it? What fees are they charging on top of commission and why?
Plan for transition. When the Act becomes law, some provisions may start immediately while others may be phased in through regulations. Understanding your baseline now helps you spot non‑compliance later.
Most importantly: do not assume this legislation replaces the need for independent legal advice on your agency agreement, brand deals, or IP rights.
The Diverge Advantage
Diverge has been sounding the alarm on the structural problems baked into traditional agency models long before the STAR Act was proposed.
Represent both the talent and the brand or multiple competing creators in the same campaign, creating inherent conflicts of interest.
Are incentivized to close any deal that generates a commission—even if that means pushing you toward lower fees, broader usage rights, or long‑term restrictions that favour the buyer.
Focus on placement, not protection, leaving you with contracts that grant unrestricted perpetual rights over your image or creations, or allow your content and likeness to be fed into AI systems without your consent or control.
Talent agents and the agencies they work for operate without regulatory oversight, do not owe fiduciary duties to performers, and are therefore not legally obligated to act solely in your best interest or maintain a strict duty of confidentiality. There is also no external body policing how your money is handled, which means your earnings can be exposed to opaque accounting, delayed payments, and conflicts of interest—with little recourse if things go wrong.
By contrast, Diverge’s lawyer‑led representation and talent management model is built on legal duties, professional regulation, and a creator‑first strategy. Although the STAR Act will require agencies to meet a minimum standard in how they handle your money, Diverge is focused on maximizing your leverage and long‑term upside in every contract you sign.
Need help understanding the intricate contracts that govern your creative work, or want to build a strategy to protect your IP long-term? Diverge Legal is here to help.
If you’re ready for representation that understands the difference between a data point and your dream, contact Diverge today.
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Diverge is not just a legal service provider. We’re your partner in building a legally sound and sustainable content creation business. We understand the unique challenges creators face and offer tailored solutions to protect your intellectual property, ensure regulatory compliance, and minimize legal risks.
Whether you’re an established influencer or an emerging creator, Diverge is here to help you focus on what you do best, while we take care of the legal complexities.
Reach out to Diverge today to learn more about how we can support your content creation journey.
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Important Notice: The information in this article is provided for general informational purposes only and is not intended as legal advice. Reading this content does not create a lawyer-client relationship. Always seek professional legal counsel tailored to your specific situation. No part of this article may be reproduced or transmitted, in any form or by any means, electronic, mechanical, photocopying, recording or otherwise, or stored in any retrieval system of any nature, without the express written permission of Diverge Legal.
