Yes. Currently, the categories of individuals who can represent clients include lawyers and registered immigration consultants, so to a degree those ghost consultants are already excluded. There is an exception for people who work for non-profit organizations and don't receive a fee to represent individuals. Non-profit organizations have good faith. They have mandates to serve the public, and it would make sense for them to be able to continue to represent individuals, regardless of not being registered.
On April 10th, 2017. See this statement in context.