In ChildFriendly Pro's 2025 Director Lunch & Learn on Alberta's Bill C-25 changes, child care operator Krystal Churcher explained that centers may now count 16- and 17-year-old Level 1 staff in ratio only when each one has a dedicated Level 2 or higher supervisor in the same room, and that licensing can now issue administrative penalties of up to $10,000 to license holders and individual educators.
What the session covered
Bill C-25 is a set of amendments to Alberta's child care regulations that Krystal Churcher described as rolled out around the end of April 2025, with the June 2025 changes now being implemented and the new penalty provisions expected in September. According to Churcher, the changes were designed to improve quality and safety in child care. They cover four areas: hiring and supervising minor staff, stronger enforcement and accountability, transparency through a public ECE certification lookup, and clearer communication. The session, hosted by the Association of Child Care Entrepreneurs (ACE) and sponsored by ChildFriendly Pro, also refreshed four regulation areas that operators had been asking about: active supervision, mixed-age group ratios, rest and nap time staff-to-child ratios, and attendance and administrative records. Churcher stressed that she does not work for licensing, that the session reflects an operator's interpretation, and that centers with specific situations should confirm with their licensing officer or Child Care Connect before changing practice.
Can 16- and 17-year-olds work in ratio in an Alberta child care center?
According to Churcher, under the Bill C-25 changes a center may hire 16- and 17-year-olds as primary child care staff and count them toward staff-to-child ratios. Churcher listed the conditions. The minor must obtain Level 1 certification within 6 months of hire, like any other staff member, and must have a standard criminal record check on file, with a vulnerable sector search requested once they turn 18. The minor must be actively supervised by an adult certified at Level 2 or higher who is in the same vicinity and available to intervene immediately, not in another program down the hall. She described the rule as one to one: one Level 2 or higher supervisor per staff member under 18. Minors may never be left alone with children, have sole responsibility for a group, or open or close the center alone. Churcher noted that this supervision requirement is non-exemptable, so an existing staffing exemption, such as those some out of school care or preschool programs hold, does not cover minor staff.
What penalties can Alberta licensing impose for non-compliance under Bill C-25?
Churcher described three new enforcement tools. First, the statutory director (licensing) can place conditions on, suspend or cancel an individual educator's certificate, for example where credentials were obtained dishonestly or qualification standards are not met. A new public ECE lookup lets anyone search an educator by name and see their certification level and whether it is in good standing. Second, licensing officers can close a specific room, program area or a whole center, so an out of school care program in non-compliance could be closed while the daycare stays open. Third, she said administrative fines of up to $10,000 can be imposed on the license holder or on educators and staff. Churcher expected fines for serious or repeat non-compliance, such as unsupervised minor staff or children at risk, rather than a single form error. In her example, a center that left a 16-year-old alone at opening received a stop order, the teen's Level 1 certificate was suspended pending investigation, and the license holder was fined $1,000.
When can centers use reduced nap time ratios in Alberta?
Churcher read the regulation as allowing relaxed staff-to-child ratios during rest periods only while all children in the group are asleep or resting. A child who is awake and sitting up, reading with a lamp on a mat, or doing quiet activities at a table is not resting and must be counted in active ratios. A participant reported that her licensing officer said children need to be truly sleeping, because a resting child can become active at any moment. In a preschool room at 1 to 8, Churcher explained that 16 sleeping children can be supervised by one staff member at the 50% rest ratio, and eight awake children need a second staff member at active ratio. If any sleeping child wakes, a third staff member must return immediately. Related rules Churcher described: infants under 12 months cannot be combined with other age groups between 8:30 a.m. and 4:30 p.m. without an exemption, and mixed-age groups are staffed by the ratio of the majority age.
Alberta Bill C-25 and ratio rules covered in the session
| Time | Key point | What centers should do |
|---|---|---|
| 04:50 | Churcher: 16- and 17-year-olds can be hired as primary staff and counted in ratio if they hold Level 1. | Confirm Level 1 within 6 months of hire and keep a standard criminal record check on file; request a vulnerable sector search at 18. |
| 07:16 | Churcher: one Level 2 or higher supervisor per minor staff member, in the same room, at all times. | Schedule each minor with a named Level 2+ mentor; never let a minor open, close or supervise alone. |
| 07:42 | Churcher: minor staff supervision rules are non-exemptable, even for programs with a staffing exemption. | Call your licensing officer before hiring a minor if your program holds a supervision exemption. |
| 12:21 | Churcher: licensing can suspend or cancel an individual educator's certificate; a public ECE lookup shows level and standing. | Look up candidates' certification before hiring and train staff that non-compliance follows their certificate. |
| 13:51 | Churcher: licensing officers can close a single room, program area or whole center. | Fix room-level hazards immediately and document the correction. |
| 14:50 | Churcher: administrative fines up to $10,000 can be imposed on license holders and on educators. | Update staff handbooks and training, and keep proof that staff have signed and been trained on policies. |
| 17:37 | Churcher: after an order, act at once and send licensing a plan of correction. | Reassign schedules, retrain staff and reply to licensing with a documented action plan. |
| 22:41 | Churcher: mixed-age groups are staffed using the ratio of the majority age group. | Recount ages and ratios at transitions, break coverage and end-of-day blending. |
| 25:33 | Churcher: infants under 12 months cannot be mixed with other age groups from 8:30 a.m. to 4:30 p.m. | Keep a separate infant room in core hours or ask licensing about an exemption. |
| 26:55 | Churcher: reduced nap ratios apply only while all children in the group are asleep or resting. | Move awake children to an active group or bring in another staff member right away. |
How ChildFriendly Pro automates this
The session described operators recalculating ratios by hand during nap time, transitions and blended end-of-day groups. In the ChildFriendly Pro demo at 37:38, Wayne Chen showed the Attendance module turning rooms red when out of Alberta ratio (one staff to five infants against 1 to 4), a nap toggle applying the reduced ratio, and the ratio switching automatically to out of school care when five OSC children were moved into a kindergarten group.
Next steps
- Register for the next Director Lunch & Learn for child care operators
- Live room ratios and digital attendance for child care centers
- Free Alberta child care mock licensing inspection and self-audit checklist
- Book a ChildFriendly Pro demo for Alberta compliance tools
