A novel solution adopted by the College to the problem of delays in resolving complaints has been to make increasing use of “never reapply” undertakings. A “never reapply” undertaking is an undertaking made by a physician to surrender his or her licence and never reapply for another licence in Ontario or anywhere else in the world. In return, the College promises not to proceed with the complaint, the investigation is terminated and the file closed. These undertakings are probably legally unenforceable both inside and outside Ontario as they would amount to an unreasonable restraint of trade and they are rarely used by other medical regulatory authorities. In the past, such undertakings were only used in the most serious cases, for example sexual abuse of a patient, but they are increasingly being used by the College as a way of disposing of less serious or unspecified complaints. The following chart shows the expansion of the use of “never reapply” undertakings between 1994 and 2020. A disadvantage of these undertakings are that they remove physicians from practice who may be able and willing to continue practicing but just wish to terminate the investigation.