Engineers and other professionals working in Ontario beware!
Key takeaways
- Using someone else’s engineering seal can lead to jail.
- You cannot “borrow” status as an engineer in Ontario. Even if you are an engineer elsewhere, you cannot hold yourself out as an “engineer” or offer engineering services to the public in Ontario without a license.
- Court orders and undertakings to regulators are not suggestions. If you agree not to use the title or not to practice, but keep doing so anyway, you are risking jail time.
- You are liable for your websites and marketing materials. Stock photos, vague references to “engineering”, and misused seals can all be treated as misrepresentation to the public.
A cautionary tale
For engineers and related professionals working in Ontario without a license from the Professional Engineers Ontario (“PEO”), Association of Professional Engineers of Ontario v. Chouchaoui et al., 2025 ONSC 5850 (“Chouchaoui”) is a cautionary decision.
In Chouchaoui, the Ontario Superior Court of Justice imposed 14 days’ jail on Mr. Chouchaoui for civil contempt after repeated misuse of a licensed engineer’s seal and continued holding out as an engineer, despite a standing injunction. The court emphasized that seals signify professional responsibility; using one to mask unlicensed practice, coupled with defiance of court directions, warranted jail time and substantial indemnity costs.
Prior to 2011, Mr. Chouchaoui, who is not an Ontario licensed engineer, had been committing several acts that all require a license or other authorization from PEO. Those acts included describing himself as an engineer; engaging in the practice of professional engineering in Ontario; offering to the public and engaging in the business of providing to the public services that are within the practice of professional engineering; and using an engineering seal. In 2011, the court issued a permanent injunction barring him from those acts.
Despite this, years later, PEO discovered that drawings submitted to the City of Windsor for building permits carried a certain engineer’s seal. Out of 48 pages, only 19 were truly sealed by that engineer; the others had the engineer’s seal copied or applied by Mr. Chouchaoui and his company.
Why does this matter?
The court was at pains to impress the gravity of the offence.
The court emphasized that fraudulently using the Ontario engineering seal and holding oneself out as an engineer in Ontario was very dangerous from a public safety perspective. The conduct is not a private matter but engages the broader public interest related to preventing unlicensed individuals from engaging in the practice of engineering. Unlicensed practice can result in significant harm to members of the public.
The court made it crystal clear that the seal is a public safety tool, a signal of competence and responsibility, and part of the promise the profession makes to the public.
Most people, whether homeowners, municipalities or businesses, cannot independently judge the technical quality of engineering drawings. They rely instead on the regulatory system. When you place a licensed engineer’s seal on a document that they did not prepare or review, you are representing to the public and the authorities that a qualified person has taken responsibility, when they have not, and hiding the fact that unlicensed practice is occurring behind the scenes.
Why jail?
Even though incarceration is a penalty of last resort, the court considered jail time appropriate in the circumstances despite several factors which might provoke sympathy for Mr. Chouchaoui.
The court was especially troubled by Mr. Chouchaoui’s:
- Deliberate misuse of the seal. This was not an accidental mis-click in some drawing software. The court found a pattern of copying or reusing the seal on drawings that had not actually been sealed by the engineer, even after the 2011 court order.
- Concealment and misrepresentation. By using the seal, Mr. Chouchaoui made it look like the work had been done, or at least properly overseen, by a licensed engineer. A city official checking the seal would see a real P.Eng. listed with PEO and have no reason to suspect anything was wrong.
- Continuing to “hold out” to the public. The company website and materials continued to suggest engineering services and expertise. Even when some changes were made, they were not enough to eliminate the misleading impression.
- Lack of genuine remorse. In court, the judge gave Mr. Chouchaoui multiple chances to acknowledge the seriousness of what he had done. Instead, he minimized the conduct (“[I] was working on one internal project that was for [me], not for someone else”, “I use the word engineering but not meant to be engineering services”, “nothing [I did] harmed the public”); blamed others, including PEO and the city; and insisted he had done nothing truly wrong.
This told the judge that he did not accept the authority of the court or the regulator, and would likely keep pushing the limits.
What might this mean for you?
The court’s decision in Chouchaoui is important not just for lawyers and regulators, but for anyone working in or around engineering in Ontario, including:
- foreign-trained engineers who have recently immigrated;
- engineers licensed elsewhere in Canada who assume the rules are identical;
- technical consultants and designers who work under or alongside engineers; and
- companies that market “engineering” services without fully understanding the licensing requirements.
If you are an engineer or other professional working in Ontario, but not licensed here (or you are thinking of doing so), Chouchaoui has some important practical lessons:
(a) Do not use the title “engineer” (or similar) unless you are actually licensed in Ontario. Even if you are fully and legitimately qualified in another country or province, or if you have a PhD in an engineering field, you cannot market yourself to the public as an “engineer” in Ontario, or offer services that fall within the regulated scope of “professional engineering”, unless you have the appropriate license or authorization from PEO.
If you want to use your qualifications, the safe route is to speak with PEO about full licensure (P.Eng.); temporary, provisional or limited licenses; or working strictly in roles that do not amount to practicing professional engineering.
(b) Never touch someone else’s seal. Even if a licensed engineer gives you their digital seal to help “speed things up”, or fails to supervise as closely as they should, you must not place their seal on documents they have not actually reviewed and approved.
If you are involved in preparing drawings or reports, make sure the licensed engineer is directly involved; make sure they control their own seal; and ensure they know exactly what they are sealing.
If a client or employer pressures you to “just put the seal on it” – that is a major red flag. Walk away and get independent advice.
(c) Be careful how you market yourself online. Websites and professional social media profiles are part of the picture. If your site or marketing materials call you an “engineer” without being licensed; use stock images of engineers and stamps; or claim expertise that implies you are practicing engineering, you are at risk of regulatory action.
If you’re unsure, it’s worth having the language reviewed by someone who understands the Ontario rules.
(d) Take regulators and court orders seriously. Even if you disagree with PEO or another regulator, ignoring them is not a strategy. If you receive a letter from PEO, are investigated, enter into an undertaking or are made subject to a court order, you need to understand the conditions and comply with them strictly. Breaking an order, especially deliberately, can escalate very quickly into contempt of court, which is what opens the door to jail.
If you feel you have been treated unfairly, the answer is to get legal advice and use proper appeal/review mechanisms, not to quietly carry on as before.
The upshot
If your work touches engineering in Ontario and you are not licensed in Ontario, Chouchaoui is a reminder to clarify your status, be honest and precise in how you describe what you do, stay on the right side of both the regulator and the courts, and when in doubt seek expert or legal advice.