Ontario government authorized to borrow up to $35 billion under new loan legislation

A new Ontario statute authorizes the provincial government to borrow up to $35 billion in total to pay off existing provincial debts and obligations or to make payments required by other legislation out of the Consolidated Revenue Fund. This borrowing authority is on top of whatever borrowing powers already exist under other Acts. Orders-in-council approving specific borrowing under this Act must be issued by December 31, 2028. Any actual borrowing under those orders must occur by December 31, 2029, unless by that date the Crown has already signed a borrowing agreement or enrolled in a borrowing program under the relevant order. Organizations that lend to or hold Ontario provincial debt, or that track provincial fiscal capacity, should be aware of this new authority.

Ontario's debt burden reduction strategy must now include metrics in its progress update

The annual debt burden reduction strategy that the Ontario government publishes with each budget must now include a progress update with specific metrics, rather than a general progress report on supporting actions. The practical change is that the update must now be measurable and quantified, not just descriptive. This affects how the government reports on its debt-reduction objectives relative to the ratio of provincial net financial liabilities to gross domestic product. Organizations that track Ontario's fiscal reporting, such as financial analysts, bond rating agencies, and public accountability groups, should expect more data-driven disclosure in future budgets.

Section 4 of the Privatization Act flagged for future repeal once Lieutenant Governor proclaims a date

An amendment has been added to the consolidated text noting that section 4 of this Act — which exempts privatization transfers from a specific provision of the Financial Administration Act — is scheduled to be repealed on a date yet to be set by the Lieutenant Governor in Council. Until that proclamation is made, section 4 remains in effect and the exemption continues to apply. Organizations involved in transactions or agreements under this Act should monitor for the proclamation date, as the repeal could affect how those transactions are governed going forward.

Ontario creates the Protect Ontario Account Investment Fund as a new designated purpose account under the Financial Administration Act

The amendment establishes a new designated purpose account called the Protect Ontario Account Investment Fund (Fonds d'investissement du compte Protéger l'Ontario). The Minister of Finance is required to set up this fund, and the Lieutenant Governor in Council may authorize amounts to be deposited into it on terms the Minister determines. Money in the fund can be spent on investments that promote innovation, infrastructure development, long-term economic growth, and other strategic provincial priorities. Unlike most government investments, expenditures for this fund are not charged to the Consolidated Revenue Fund in the same way—a specific carve-out removes that default rule for this fund. Returns and proceeds from investments flow back into the fund, though the Minister can direct some proceeds to remain in the Consolidated Revenue Fund instead. Regulations may be made prescribing terms, conditions, and restrictions on the securities and instruments the Minister may hold for this fund's purposes.

Ontario pension law expanded to allow variable life benefits, new wind-up rules, and extinguishment of untraceable members' benefits

Ontario's Pension Benefits Act has been amended to introduce a new type of pension payment called a "variable life benefit" — a pooled, non-account-based pension paid from a dedicated fund whose amount can fluctuate based on investment returns, mortality experience, and actuarial assumptions. Pension plans may be designed to offer this option, and members with defined contribution or additional voluntary contribution balances may elect to transfer those funds into a variable life benefit fund before retiring. A parallel set of partial wind-up rules (sections 77.0.1–77.0.7) has been added specifically for plans offering variable life benefits, since the general bar on partial wind-ups still applies to other plan types. A new section (102.5) allows plan administrators to apply to the Chief Executive Officer to extinguish the rights of former or retired members who appear to be over 100 years old and cannot be located, with defined consequences for misapplied consents. The Guarantee Fund monthly benefit threshold for wind-ups on or after March 26, 2026 has also been increased from $1,500 to $3,000 per month. Most of the new variable life benefit provisions are not yet in force and require a proclamation order.

New law removes bus-parking obligation on Toronto's Block 18C and shields government from related lawsuits

A new Ontario statute eliminates the requirement under a City of Toronto by-law that bus parking be provided on Block 18C, a parcel of land in downtown Toronto near the former SkyDome. The law also bars virtually all legal claims—including damages, injunctions, and contractual remedies—against the Crown, municipalities, and their officials arising from this change or from anything done under the related 2002 Skydome Act (Bus Parking); judicial review and constitutional challenges remain available. The government gains authority to make regulations that can terminate, suspend, or amend any contract or agreement tied to Block 18C's development, generally without paying compensation. Anyone who held rights under existing contracts or the old by-law's bus-parking requirement should take note that those rights may be extinguished or altered by regulation. Parties considering legal action related to Block 18C bus-parking arrangements should be aware that most court, arbitration, and administrative proceedings on this topic are now blocked.

Status Indians now excluded from Ontario's 'foreign national' definition for land transfer tax purposes

The definition of 'foreign national' in Ontario's Land Transfer Tax Act has been updated to explicitly exclude persons registered as Indians under the federal Indian Act. Previously, the definition tracked the federal Immigration and Refugee Protection Act without any carve-out. As a result of this change, registered Indians are no longer treated as 'foreign nationals' or 'foreign entities' under the Act, which affects how the non-resident speculation tax and related provisions apply to them. Registered Indians purchasing land in Ontario should be aware they now fall outside those foreign-entity provisions. Anyone advising on land transfers involving registered Indians should review how this exclusion changes their tax obligations under the Act.

New regulation sets design, maintenance, training and record-keeping rules for all elevating work platforms on Ontario construction projects

Ontario has introduced a standalone regulation governing elevating work platforms (EWPs) — including mobile elevating work platforms (MEWPs), mast climbing work platforms and vehicle-mounted aerial devices — on all construction projects. Every EWP must be engineer-designed and certified to the applicable CSA standard, equipped with guardrails and rated-load signage, and inspected daily before use. Owners must keep permanent maintenance and inspection records dating back to the original purchase date or May 1991, whichever is later, and attach an up-to-date inspection tag near the operator's station. Employers must ensure MEWP operators complete a formal theory-and-practical training program valid for five years, with make-and-model familiarization required when training was not specific to the equipment in use; training records must be kept and provided to workers or inspectors on request. Workers operating other types of EWPs must receive oral and written instruction, including a hands-on demonstration, before first use.

Asbestos rules to accept CSA-certified respirators alongside NIOSH-approved ones starting mid-2026

Amendments scheduled to take effect add the CSA Group (CSA) as an accepted respirator certification body alongside the existing NIOSH standard for asbestos work on construction projects and in buildings. Workers and employers will be able to use respirators approved by either NIOSH or CSA when asbestos exposure controls require respiratory protection. The respirator filter designations in Table 2 are also being updated to reflect current NIOSH and new CSA filter coding conventions (e.g., N100, CA-N100, R100, CA-R100, P100, CA-P100 replacing the older hyphenated codes). Employers and safety managers should review their respirator procurement and worker training to ensure equipment meets either the NIOSH or CSA approval standards once the changes are in force.

Hard hats must meet side-impact standards and section 22 rules tightened; several elevating work platform sections to be revoked

Two sets of future changes have been added to Ontario's construction regulation. First, hard-hat requirements are being upgraded: workers who may be exposed to side-impact hazards will need headwear that meets the Type 2 (CSA Z94.1) or Type II (ANSI Z89.1) standard; all other workers will still need headwear meeting those same standards (but without the side-impact-specific Type 2 requirement). A new rule also requires a chin strap or other retention system whenever site conditions could cause a hard hat to dislodge. Second, the current rules for elevating work platforms covering design, maintenance records, inspection tags, operator training, operating limits, and operator manuals (sections 143–149) are all being revoked, which likely signals replacement by a different regulatory framework. Construction employers and safety officers should assess their current hard hat inventory against the upcoming Type 2/Type II requirements and monitor for any replacement rules on elevating work platforms.

Future amendments flagged: indemnity approval requirement for Ontario health Agency and Service Organization set to be removed

The consolidated text of the Connecting Care Act, 2019 now includes prospective amendment notices signalling that, once brought into force by Lieutenant Governor in Council order, the requirement for Agency and Service Organization indemnities to be pre-approved under the Financial Administration Act will be repealed. At the same time, the cross-reference to that approval requirement in the duty-of-care provisions will be removed. These changes are not yet in force and have no immediate legal effect. Organizations governed by these provisions — Ontario Health (the Agency) and designated Service Organizations — should be aware that the indemnification approval process may eventually change. No action is required until a proclamation date is announced.

Ontario Taxation Act updated: dividend tax rates, small business rate, beer credit, Trillium Benefit thresholds, and procedural rules all revised

Ontario's Taxation Act has been amended in several areas. The provincial gross-up rate applied to eligible dividends received by individuals is being reduced for tax years after 2026 (from 22.895% to 15.2283%), and the small business corporate tax rate will rise from 8.3% to 9.3% for days after June 30, 2026, narrowing the gap with the general rate. The Ontario Trillium Benefit payment rules are updated so that, starting with the 2025 base taxation year, the threshold for choosing a single annual payment rises from $360 to $500. The Ontario Computer Animation and Special Effects Tax Credit now has a clearer test for what prior-year labour expenditures reduce the current claim, and the Ontario Made Manufacturing Investment Tax Credit is now limited to expenditures incurred before January 1, 2027. The small beer manufacturers' tax credit formula is revised with new per-litre rates for the March 2026–February 2027 sales year and for years starting March 1, 2027. New procedural provisions incorporate additional federal assessment and evidentiary rules into the Ontario Act.

Ontario eliminates volume and environmental taxes on beer, wine and spirits; raises basic beer tax rates and restructures spirits tax by alcohol content

Ontario's Liquor Tax Act has been restructured to remove the separate volume tax and environmental tax that applied to beer, wine, wine cooler, and spirits purchased from licensed retail stores — those charges no longer exist. The basic tax rate for beer has increased: draft beer moves from 72.45 cents to 90 cents per litre, and non-draft beer from 89.74 cents to $1.18 per litre, with microbrewer discount amounts adjusted accordingly. Spirits sold at distillery retail stores are now taxed on a tiered basis by alcohol content (20%, 25%, or 30.75% of retail price depending on whether ABV is 7.1% or below, between 7.1% and 18%, or above 18%), replacing the previous flat 30.75% rate. The retail price calculation formulas for wine, wine cooler, and spirits have been simplified into a single algebraic formula, removing the steps that previously backed out volume and environmental taxes. The definition of 'spirits cooler' has been removed from the Act, and transition rules protect collectors and purchasers who paid tax at old rates before the changes took effect. Businesses that collect or remit liquor tax — including beer manufacturers, microbrewers, wineries, and distilleries — should review their systems to apply the new rates and simplified formulas.

Ontario expands the election to treat funded benefit plans as unfunded for tax purposes, with new ministerial regulation powers

Planholders of funded benefit plans can now elect to have their employer health tax on benefit plan contributions calculated under the unfunded-plan rules (based on benefits paid rather than contributions made). Previously this election was only available to qualifying trusts with excess assets; it is now open to any funded benefit plan planholder. The Minister gains authority to prescribe limitations on which plans may elect, how long elections last, and to make regulations overriding the normal transition rules when an election is made or revoked — including regulations that can apply retroactively. Planholders who think they may benefit from switching to unfunded-plan tax treatment should review whether they qualify and how to file an election in the form and manner the Minister approves. The earlier disclaimer about the consolidation being affected by retroactive provisions has been removed, suggesting the retroactive provisions have now been incorporated.

Future repeal of two Financial Administration Act exemptions flagged in Electricity Act consolidation

The consolidated text of the Electricity Act now includes editorial notes signalling that two provisions — one exempting certain Part transactions from section 28 of the Financial Administration Act (s. 51), and another doing the same for securities-related orders involving Hydro One and Ontario Power Generation (s. 122(3)) — are scheduled for repeal on a date still to be set by the Lieutenant Governor in Council. No repeal has taken effect yet; these are prospective amendments recorded in the statute's amendment history. Entities involved in transactions covered by those exemptions — particularly those relying on the carve-out from Financial Administration Act approval requirements — should be aware that those exemptions will eventually disappear and plan accordingly.

Ontario's 36 conservation authorities will be amalgamated into 9 regional authorities starting February 2027

Beginning on the 'transition date' (currently set for February 1, 2027, subject to change by regulation), Ontario's existing 36 conservation authorities will be merged into nine newly named regional conservation authorities, plus one renamed authority (the Lakehead Region Conservation Authority becomes the Northwestern Ontario Regional Conservation Authority). All assets, liabilities, employees, contracts, permits, licences and ongoing proceedings transfer automatically to the new authority, and employment is deemed continuous with no termination or constructive dismissal. A new transition framework introduces transition committees (chaired by Agency-appointed project executives) to prepare amalgamation plans for each new authority, and places temporary prohibitions on establishing, enlarging, merging or dissolving authorities outside this process. Existing conservation authorities, their member municipalities, employees and parties to contracts or agreements with those authorities should begin reviewing how the amalgamation rules, member appointment processes, watershed council requirements and revised governance provisions will apply to their organization.

New advisory committee will screen WSIB board appointments before they reach the Minister

Pending proclamation, a formal advisory committee must be established to vet and recommend candidates for most WSIB board member positions before the Minister can propose names to the Lieutenant Governor in Council. At least a majority-plus-one of the board's appointed members (those in the general category) must come from candidates the committee recommends, and the committee itself must include both public members selected through an open process and individuals with occupational health and safety backgrounds. Candidates must first apply through the Public Appointments Secretariat. The board of directors also gains a new formal channel to recommend in writing that a member's appointment be revoked, which the Minister must consider. These changes are not yet in force and will take effect on a date to be set by order.

Respirator approval rules for designated substances expanded to recognize CSA Group certification

Starting mid-2026, respirators used under Ontario's Designated Substances regulation will be accepted if approved by NIOSH, by the CSA Group (a newly recognized certifier), or by another agency whose protection is judged equivalent to either NIOSH or CSA. Previously, only NIOSH approval or an equivalency opinion was required. For asbestos protection specifically, the filter designation codes are also being updated: the current 'N-100, R-100 or P-100' labelling will be replaced with expanded codes including 'CA-N100, CA-R100 and CA-P100' to align with CSA standards. Employers who supply workers with respirators for designated-substance work should verify that their equipment selections and purchasing specifications reflect the updated approval criteria and filter codes before the changes take effect.

Respirator approval rules updated to recognize CSA Group certification alongside NIOSH

Starting mid-2026, respirators provided to workers can be approved by the CSA Group (CSA) as an alternative to NIOSH approval, not just by NIOSH or a qualified-opinion-backed third party. The amendment adds CSA as a recognized certifying body in the respirator selection requirements and updates the filter designation codes for asbestos work (e.g., 'N-100' becomes 'N100' or 'CA-N100', and equivalent changes for R and P series filters). Employers who select and provide respirators will need to ensure their equipment meets the updated approval and filter labelling standards. Anyone currently specifying respirators for workers—particularly for asbestos exposure—should check that the filter designations in their written programs match the new codes.

Ontario's municipal freedom of information law gets major overhaul: new privacy breach rules, staged-access plans, and whistleblower protection

Ontario has made sweeping changes to the Municipal Freedom of Information and Protection of Privacy Act affecting how municipal institutions handle access requests and protect personal information. Institutions can now propose a staged access plan when a request is unusually large or burdensome, and requesters must respond within 30 business days or risk being deemed to have abandoned their request. Response deadlines are shifting from calendar days to business days, and the main response period is increasing from 30 to 45 business days, with a new second extension available in limited circumstances. Institutions will be required to conduct written privacy impact assessments before collecting personal information, implement reasonable safeguards to protect it, and report thefts, losses or unauthorized disclosures to the Privacy Commissioner and affected individuals when there is a real risk of significant harm. A new whistleblower provision allows anyone with reasonable grounds to report suspected contraventions confidentially to the Commissioner. The personal information bank concept and related index requirements are being repealed, and the Commissioner gains new powers to review an institution's information practices and order corrective action.

Ontario's Freedom of Information Act overhauled: ministers' records excluded, new staged-access rules, longer response times, and data integration changes

Ontario has made sweeping changes to its Freedom of Information and Protection of Privacy Act. Most significantly, records held by ministers of the Crown or their offices are now excluded from the Act entirely, with this exclusion applied retroactively — even existing access requests and prior orders are nullified to the extent they relate to such records. For large or complex information requests, institutions can now propose a staged access plan, pausing the response clock while the requester considers it; requesters who do not respond to a plan within 30 business days are deemed to have abandoned their request. The standard response window for access decisions changes from 30 calendar days to 45 business days, and most other time limits throughout the Act are converted from calendar days to business days. The personal information bank regime (the obligation to maintain and publish an index of personal information collections) is repealed. In the data integration sphere, responsibility for setting data standards shifts from the Privacy Commissioner to the Chief Digital and Data Officer, though the Commissioner gains a new formal power to comment and make recommendations on privacy implications. Institutions and requesters should review their internal processes for handling FOI requests, staged-access responses, appeal deadlines, and personal information cataloguing obligations.

Ontario eases business permit-service-standard rules and cuts compliance reporting to twice a year

Two changes take effect together on a future date. First, the rule requiring separate service standards for 'normal' versus 'not normal' permit applications is replaced: ministries will now distinguish 'typical' from 'not typical' circumstances, and a service standard may expressly exclude from its time commitment any period spent waiting on external processes or on Crown duty-to-consult obligations with Indigenous communities. Second, the quarterly compliance-reporting requirement for ministries is reduced to semi-annual reporting — twice a year instead of four times — with reports due by the end of January and July each year. Businesses that track how quickly Ontario ministries commit to processing permit and licence applications should note that ministry timelines may now formally exclude delays caused by third-party processes or consultation requirements, which could affect how published service standards are interpreted.

Victoria Day removed from the list of statutory retail holidays under Ontario's Retail Business Holidays Act

Victoria Day has been removed from the definition of "holiday" in Ontario's Retail Business Holidays Act, meaning it is no longer a designated closing day for retail businesses under that law. Retailers who previously had to close or obtain an exemption to open on Victoria Day will no longer face that requirement based on this Act. This change applies province-wide, except the City of Toronto, which has always been exempt from this Act. Retail operators and compliance teams should review their holiday operating policies and schedules to reflect that Victoria Day is no longer a restricted day under this legislation.

Metrolinx must follow new notice and consultation steps before ordering access to municipal roads and rights of way

Metrolinx now has explicit procedural obligations before it can issue an order requiring access to, or alteration of, a municipal highway or right of way. Before issuing such an order, Metrolinx must make good-faith efforts to meet any technical requirements and give due consideration to a set of listed factors. It must give the provincial Ministry of Transportation at least 20 days' written notice (with a detailed summary of negotiation steps taken), and the affected municipality at least 15 days' notice. If a municipality fails to comply with an order, Metrolinx must notify the Ministry at least 15 days before filing the order in the Superior Court of Justice. Metrolinx may revise or cancel an order, but must give both the Ministry and the affected municipality at least 15 days' advance notice before doing so. Municipalities and Metrolinx project teams involved in transit construction affecting local roads and rights of way need to be aware of these new steps.