As our blog this week, an update from law firm Norton Rose Fulbright on Bill C-39, the Building Canada Strong Act, and its goal of ‘One project, one review, one year.’ By Jay LeMoine:
This bill amends several key pieces of legislation with the objective of broadening Canada’s access to global markets and supply chains to build a stronger, more independent and sustainable economy by:
Following quickly on the heels of Prime Minister Carney’s Investment Summit with its focus on Canadian infrastructure projects, the autumn session of Parliament opened on September 21, and the government promptly introduced Bill C-39 (Building Canada Strong Act). This bill amends several key pieces of legislation with the objective of broadening Canada’s access to global markets and supply chains to build a stronger, more independent and sustainable economy by:
- bringing “greater speed, certainty, and predictability to infrastructure project reviews”; and
- reducing redundancy and regulatory approval delay for major projects.
The bill supplements legislation passed in previous sittings that set up the framework for more efficient delivery of “projects of national interest.”
Bill C-39 also amends employment and labour legislation applicable to federally regulated employment. For more information on that aspect of the bill, see our recent update.
One project, one review, one year
For infrastructure project proponents and investors, the key theme of the bill is “one project, one review, one year.” The government seeks to provide greater certainty and a single point of contact for regulatory approvals.
The bill includes:
- amendments to the Impact Assessment Act:
- requiring decisions for a designated project within one year of the proponent providing the required information (details of this timeline trigger have not yet been determined);
- empowering the minister to issue a single decision document that bundles together multiple federal permits, approvals, conditions and mitigations measures applicable to a project;
- amendments to the Building Canada Act (especially of interest for mining, critical minerals, energy and telecommunication corridor projects):
- permitting the federal Cabinet to designate “regions of national interest”; and
- once designated, providing a framework to allow certain developments in those regions to be considered “pre-approved,” subject to conditions; and
- the creation of a new Crown Consultation Hub to support and coordinate consultation with Indigenous Peoples.
Energy, pipelines and resources
Other key amendments include:
- making the Canada Energy Regulator (CER) the sole assessor of applications for pipelines, designated power lines and offshore renewable energy projects and requiring decisions on those projects within one year of the required information being received;
- for designated nuclear and uranium projects, making the Canadian Nuclear Safety Commission responsible for carrying out relevant reviews and assessments.
- expanding the authority of the applicable ministers under the following legislation to assist in meeting the one-year decision timeline for a designated project: Building Canada Act, Species at Risk Act, Canadian Navigable Waters Act, Fisheries Act, and Canadian Environmental Protection Act.
It should be noted the government has emphasized that:
- while the amendments change which regulatory body will lead a project assessment, they do not alter the requirements or standards that apply; and
- the duty to consult with Indigenous Peoples and obligations under modern treaties are unaffected.
What does this mean for major projects?
Prior to the changes proposed in Bill C-39, infrastructure projects often required multiple consultation processes involving multiple decision makers. As a result, the timeline for projects from submission to the federal decision often took many years and, in some cases, more than a decade.
Under Bill C-39, the project approval process will be streamlined to involve fewer governmental departments and a more streamlined process to ensure decisions are rendered more quickly.
The bill is now at second reading in the House of Commons. It still has to go through committee study, report stage and third reading, followed by the full process in the Senate. Committee hearings are likely to be the main opportunity for industry, Indigenous groups and other stakeholders to influence the final wording. It will also be interesting to see how:
- the changes to federal legislation will operate alongside relevant provincial legislation, which is also critical to project approval processes; and
- the key amendments will be operationalized, including details around timeline triggers, timeline extensions, criteria and scope of designated areas of national interest, as well as the processes for coordinating Indigenous consultation.
Footnote: The bill passed second reading in the House of Commons on October 8, and has been referred to a legislative committee for detailed study.
- The original story as posted on Lexology: https://bit.ly/47XxnvC
Posted here 14 October 2026
