# Verification record — `ca/on/registration/business-incorporation` v1.0.0 This file is the **source-review record** for this document version, per the [`manual-source-review-v1`](../../../../../practices/manual-source-review-v1.md) practice. ## Current claim - **`status`:** `draft` - **`verification.method`:** `manual-source-review-v1` - **`verification.lastVerifiedAt`:** `2026-07-02` The document was derived directly from the Ontario Central Forms Repository's official fillable Form 5351E (edition 2025/01). It remains `draft`, not `verified`. ## Sources examined - **Document `(id, version)`:** `ca/on/registration/business-incorporation` / `1.0.0` - **Spec version:** GovSchema `0.3.0` - **Authority:** Ontario Business Registry (Ministry of Public and Business Service Delivery and Procurement, "OBR"). - **Primary source:** Form 5351E (2025/01), "Articles of Incorporation — Business Corporations Act" — — retrieved directly (HTTP 200, no access block encountered; this `forms.mgcs.gov.on.ca` / `ontario.ca`-family domain is unaffected by the `canada.ca` block recorded for `ca/cra/individual-income-tax-and-benefit-return-t1`). - **Field extraction method:** this is a **dynamic Adobe LiveCycle Designer (XFA) form**, not a flat AcroForm — `pdfjs-dist`'s ordinary `getDocument().getFieldObjects()` returns `null` for it, and rendering the document without XFA support produces only a static placeholder page reading "The document you are trying to load requires Adobe Reader 8 or higher." Fields were instead extracted by opening the document with `enableXfa: true` and reading `PDFDocumentProxy.allXfaHtml` — pdfjs's own flattened HTML-equivalent tree of the XFA template — which exposes every `input`/`select` element's `dataId` (the XFA field's internal name), `aria-label` (the field's full section/question text as read by assistive technology), and constraints such as `maxLength`. This is a different extraction technique from the AcroForm `getFieldObjects()`/annotation approach used for `us/irs/employer-identification-number-ss4` and `ca/cra/individual-income-tax-and-benefit-return-t1`, and is recorded here as the reference method for any future GovSchema XFA-form authoring. - **Retrieved / reviewed:** 2026-07-02. - **Reviewer:** GovSchema Engineering (Standards Engineer — initial authoring source review). ## What was confirmed against the source | Source element | Field(s) | |---|---| | Section 1, Contact Information | `contactFirstName` through `contactEmail` | | Section 2, Corporation Name (number name / English proposed name / NUANS report) | `corporationNameType`, `numberNameLegalElement`, `proposedCorporationName`, `nuansReportReferenceNumber`, `nuansReportDate` | | Section 3, General Details | `requestedIncorporationDate`, `primaryActivityCode`, `officialEmailAddress` | | Section 4, Address (Standard Address only) | `registeredOfficeStreetNumber` through `registeredOfficePostalCode` | | Section 5, First Director(s) | `directorCountType` through `directorIsAlsoIncorporator` | | Section 6, Shares and Provisions | `sharesProvisionsTextType` through `otherProvisions` (including the form's own stated 900,000-character-per-text-box maximum) | | Section 7, Incorporator(s) — Individual | `incorporatorFirstName` through `incorporatorLastName` | | Section 8, Authorization / Required Signature | `authorizationConfirmed`, `signatureFullName`, `documents[].authorizationAttestation` (statement quoted verbatim) | `maxLength` constraints on every `string` field were taken directly from the XFA field's own `maxLength` attribute, not estimated. ## What is NOT independently confirmed / out of scope - **French and bilingual corporation names.** Section 2 also offers a French name, a combined English-and-French name, and an equivalent-but-separate English/French name pathway (each with its own NUANS Report sub-fields, e.g. `corpNameF`/`refnoF`/`dateF` in the source's internal field names). Only the English-name pathway is modelled, consistent with the English-only scoping already used across this registry (e.g. `gb/companies-house/company-incorporation-in01`, `ie/cro/company-incorporation`). - **The legal-opinion-for-identical-name pathway** (Section 2's "Select this if you have a Legal Opinion for an identical name" checkbox and its four-part lawyer-opinion declaration, lawyer name/firm/phone/email, and address). A rare pathway (used only when incorporating under a name identical to an affiliated, successor, or dissolved corporation's name), out of scope. - **Lot/Concession (rural) registered office addressing** (Section 4's alternative to the Standard Address). Out of scope; only the Standard Address sub-fields are modelled. - **Multiple directors.** Form 5351E supports adding any number of directors via a repeatable "Add Director (+)" control; this document scopes to a single first director, the same single-entity scoping convention used for `ie/cro/company-incorporation`'s single director/secretary/subscriber. GovSchema v0.3's field model is flat with no array/repeated-group construct (SPEC.md §6.1), so a genuinely multi-director schema would need either a future array-capable spec version or a fixed set of numbered `director2FirstName`-style fields, neither of which this cycle introduces. - **Corporate incorporators** ("Corporation registered in Ontario" and "Corporation not registered in Ontario," each with their own `corporationName`/OCN-or-address/signing-representative field set). Out of scope; only the single individual incorporator pathway is modelled. - **The exact sub-field breakdown of `directorAddressForService` and `incorporatorAddress`.** The live form's own developer notes, printed directly on page 1 of the PDF, state: *"Section 5: Is this director also an Incorporator? For 'No' option subform is manually hidden not in the code[.] Section 2, 5, Section 7: Address for Service: Canada, USA, International subforms are manually hidden not in the code."* Consistent with that note, the static `allXfaHtml` extraction surfaces the Canada/U.S.A./International country-choice checkboxes for the director's address-for-service (Section 5) and the incorporator's registered/head office address (Section 7), but **no** corresponding address-line/city/ province/postal-code input elements anywhere beneath them — unlike the registered office address (Section 4), whose Standard Address sub-fields *are* fully present in the static extraction. This is a genuine tool/source limitation, not a search miss: the same pattern was independently checked and confirmed absent for all three "Address for Service"/country-choice instances in the document (Section 2's now-out-of-scope lawyer address, Section 5, and Section 7). Rather than fabricate a plausible-looking address field set unconfirmed against the live form, `directorAddressForService` and `incorporatorAddress` are modelled as opaque `type: object` fields (SPEC.md §6.2, "a composite value carried opaquely") with a description noting the expected shape. **Open item for a future revision:** a reviewer who can drive the live, JavaScript-enabled form (e.g. in Adobe Reader, or the Ontario Business Registry's own online filing interface) should confirm the exact address sub-fields and, if GovSchema still lacks a nested-object field model at that time, either flatten them here (MINOR version bump, additive) or record the gap against the flat-fields limitation already noted in SPEC.md §16. - **The exact permitted values for `numberNameLegalElement`.** Form 5351E's "Legal Element for the Number Name" field carries no visible enumerated option list in the static extraction (only an info-icon tooltip, not rendered as text). Commonly known OBCA legal elements are "Incorporated" / "Inc.", "Limited" / "Ltd.", and "Corporation" / "Corp.", but this was not independently confirmed against the live form's own picklist (if any), so the field is modelled as free text rather than a closed `enum` — avoiding asserting exact values not confirmed from source. - **Fees.** Not modelled as authoritative data, consistent with every other schema in this registry. ## Scope and jurisdiction notes - Conditional requiredness is expressed with `requiredWhen` (GSP-0013), targeting spec v0.3, following the `nz/ird/individual-tax-return-ir3` and `ca/cra/individual-income-tax-and-benefit-return-t1` precedent. - `directorIsResidentCanadian` and `directorIsAlsoIncorporator` are marked `fieldRole: eligibility`: both are binary gate questions on the source form. `directorIsResidentCanadian` is retained because the live form still asks it, but is documented as informational-only since the OBCA's resident- Canadian-director requirement was repealed effective **2021-07-05** by the *Better for People, Smarter for Business Act, 2020* (confirmed via independent secondary coverage — Stikeman Elliott, Fasken, DLA Piper, Bennett Jones, and Dentons client alerts, all dated April-July 2021, corroborating the same repeal date and mechanism). `directorIsAlsoIncorporator` genuinely gates `directorAddressForService`'s requiredness, per the form's own developer note quoted above. - `crossFieldValidation`'s `maximumDirectorCountNotLessThanMinimum` rule applies the `compare` shape (SPEC.md §8.3) to `maximumDirectorCount`/ `minimumDirectorCount`, both of which are only populated when `directorCountType` is `minimum_and_maximum`; a consumer evaluating this rule against a `fixed_number` submission (where neither field is present) has nothing to compare and should treat the rule as vacuously satisfied, the same way `requiredWhen`/`visibleWhen` treat an absent/hidden field's requiredness as `false` (§6.7) — no registry schema has yet exercised a `compare` rule against optionally-absent fields, so this interpretation is flagged here for reviewer attention rather than assumed silently. - This is the **fourth** company-formation jurisdiction in the registry, after `gb/companies-house/company-incorporation-in01`, `us/ca/sos/business-entity-llc-formation`, and `ie/cro/company-incorporation` — closing the catalog candidate note's "fourth company-formation jurisdiction" gap. ## Path to a `verified` claim (next step) To advance to `status: verified`, a reviewer drives the live Ontario Business Registry online filing flow (or the JavaScript-enabled PDF in Adobe Reader) with a mock filing, confirms the `directorAddressForService`/ `incorporatorAddress` sub-field breakdown and the `numberNameLegalElement` picklist noted above, and records the outcome here — shipping a new schema version if discrepancies are found (VERSIONING.md §3, immutability). ## Re-verification Per the practice's Cadence, `nextReviewBy` is set to **2027-01-01** (6 months).