In an era characterized by tariff uncertainty and intensifying geopolitical pressures, governments across Canada are attempting to create ideal conditions for economic development using the same lever: speed.

With the introduction of An Act to accelerate the granting of the authorizations required to carry out priority national-scale projects (“Bill Q-5”), Québec is following in the footsteps of the federal government and Ontario by adopting legislative measures to accelerate the completion of major economic and infrastructure projects.

Combined with Ontario’s Protect Ontario by Unleashing our Economy Act, 2025 (“Bill 5”) and the federal Act to enact the Free Trade and Labour Mobility in Canada Act and the Building Canada Act (“Bill C‑5”), Québec’s initiative confirms a clear trend—when the economy is increasingly unstable, governments respond by streamlining authorization processes, centralizing decision-making, and prioritizing projects deemed essential to economic resilience.

Below, we outline the main features of the three “Bill 5” initiatives and explain how Québec’s approach aligns with a broader national trend.

Same economic context, three different legislative responses

Although each bill reflects its own constitutional and political context, they all address a common concern: reducing Canada's vulnerability to global economic volatility, including tariffs and resulting trade disruptions, and delays in the implementation of strategic projects.

At high level, the three bills pursue similar objectives:

  • Reduce regulatory friction for priority projects
  • Reduce delays to obtain approvals
  • Give governments greater flexibility to respond to economic emergencies

The differences lie in how each piece of legislation chooses to achieve these goals.

Québec's Bill Q-5: A coordinated economic response

On December 9, 2025, Québec Finance Minister Éric Girard introduced Bill Q-5, aimed at accelerating priority economic and infrastructure projects. The bill reflects Québec's recognition that maintaining its economic competitiveness requires tools equivalent to those already adopted elsewhere in the country.

Québec’s approach is the most integrated of the three laws from an administrative standpoint.

What it proposes

  • The government may designate certain large-scale strategic projects as “priority and national in scope” for a limited time.[1]
  • A single government authorization may be issued to replace several permits or authorizations otherwise required under provincial laws and regulations listed.[2]
  • This authorization may include the conditions from the legislative regimes it replaces.[3]
  • Preparatory work may be authorized prior to the issuance of the final authorization.[4]
  • Obligations relating to inspection, enforcement, and consultation with Indigenous peoples remain applicable.[5]

Differentiators

The Québec model centralizes authorization authority while maintaining the substantive requirements of existing laws. Rather than eliminating regulatory obligations, the Act consolidates them into a single authorization instrument issued by the government.

This structure is particularly relevant for projects that would otherwise require authorizations under multiple provincial regimes, including environmental, mining, land use planning, or municipal legislation.

Ontario Bill 5: Stimulating growth through deregulation

The Ontario law is based on a series of amendments to several statutes, combined with the creation of new regulatory tools.

What it proposes

  • Special economic zones in which certain legislative and municipal requirements may be modified or waived for designated projects.[6]
  • Amendments to laws governing environmental assessment, species protection, heritage, mining, energy, and procurement.[7]
  • Procurement restrictions based on geographic origin in certain contexts.[8]
  • Fast-tracked processes for projects related to strategic mineral supply chains.[9]
  • Limitations on certain legal actions and claims for compensation arising from legislative changes.[10]

Differentiators

Ontario’s approach is based on targeted amendments to specific laws and exemptions for certain projects or areas, rather than a single authorization mechanism. As a result, a project’s regulatory path will depend on specific sectors and the applicable legislative tools.

Federal Bill C-5: Speed as a national economic strategy

The federal legislation emphasizes interprovincial economic integration and the streamlining of federal authorization processes.

What it proposes

  • Establishing mutual recognition of goods, services, and labour that comply with provincial or territorial requirements.[11]
  • Authorizing the Governor in Council to designate certain projects as being of national interest.[12]
  • Presuming that certain federal decisions, findings, and opinions required for designated projects have been made.[13]
  • Issuing a single federal document setting out the applicable conditions, which is deemed to constitute the required federal authorizations.[14]
  • Obligations for monitoring, reviewing, and reporting with respect to designated projects.[15]

Differentiators

Bill C-5 does not change provincial authorization regimes. Instead, it aims to simplify federal processes by consolidating federal authorizations and reducing duplication within federal jurisdiction. The presumption provisions apply only to federal statutory requirements and operate subject to conditions imposed by the designated minister.[16]

This framework is particularly relevant for projects requiring multiple federal approvals or involving interprovincial or federally regulated activities.

What this means for project proponents

Taken together, the three bills with the number 5 in them illustrate a clear national direction:

  • Governments are increasingly willing to expedite regulatory procedures in exchange for greater economic certainty.
  • Infrastructure and industrial projects with a strong economic rationale are more likely to benefit from expedited processes.
  • Discretionary power is increasingly centralized at the executive level.

These changes create opportunities for developers but also require that they be extremely careful when navigating legal issues. Accelerating processes does not eliminate legal risks—it shifts them. Developers will need to understand how each jurisdiction defines priority projects, exercises discretionary power, and coordinates approvals.

Members of our practice group are closely monitoring these developments and their practical implications. If you have questions about the impact of these legislative changes on current or planned projects, or if you would like to discuss opportunities and risks, please contact the authors of this article.


[1] Act to accelerate the granting of the authorizations required to carry out priority national-scale projects, Bill 5 (introduction – December 9, 2025) 2nd sess., 43rd legis. (Qc), s. 4.

[2] Id., s. 13.

[3] Id., s. 15.

[4] Id., s. 12.

[5] Id., sections 3 and 50.

[6] Protect Ontario by Unleashing our Economy Act, Bill 5 (Royal Assent – June 5, 2025), (Ont), Schedule 9.

[7] Id., Schedules 2, 3, 5, 6, and 7.

[8] Id., s. 25.32(5).

[9] Id., Schedule 5.

[10] Id., Schedules 1, 5, 6, 7, and 9.

[11] An Act to enact the Free Trade and Labour Mobility in Canada Act and the Building Canada Act, Bill C-5, (Royal Assent – June 26, 2025), 1st sess., 45th parl., Part 1, ss. 7-10.

[12] Id., Part 2, s. 5(1).

[13] Id., Part 2, section 6(1).

[14] Id., Part 2, s. 7.

[15] Id., Part 2, s. 23.1.

[16] Id., Part 2, sections 6 and 7.