On September 21, 2026, the Government of Canada released the first draft of Bill C-39, the An Act respecting certain measures to strengthen the economy. Bill C-39 proposes sweeping changes to various pieces of legislation, including the Impact Assessment Act, Canada Energy Regulator Act, Canadian Environmental Protection Act, Canada Transportation Act, Canadian Navigable Waters Act, and Canada Labour Code, among others.
The legislation seeks to accelerate the development of major projects by establishing a one-year target for federal reviews and decisions following the submission of a comprehensive application. It provides for the coordination of consultations with Indigenous peoples of Canada in respect of pipelines, designated power lines and offshore renewal energy projects with federal authorities. It also seeks to strengthen Canada's trade and transportation infrastructure, support market diversification and supply chain resilience, and modernize the federal labour framework while strengthening protections for federally regulated workers.
Concurrently with the release of Bill C-39, Cabinet issued a Directive which applies to all federal departments and agencies responsible for regulatory reviews and decisions related to projects. The Directive establishes a one-year target for federal decisions on major projects, with the clock generally starting once a proponent submits a comprehensive application and all required information and studies (although the timing varies depending on whether the project requires an impact assessment, a single federal permit, or multiple federal permits).
Given that Bill C-39 has only recently received first reading in the House of Commons, it remains subject to the legislative process and may be amended before being enacted. We will continue to monitor developments and keep clients apprised of any significant changes as the legislation progresses.

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