Yannick Beaudoin
Partner
Article
4
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.
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:
The differences lie in how each piece of legislation chooses to achieve these goals.
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.
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.
The Ontario law is based on a series of amendments to several statutes, combined with the creation of new regulatory tools.
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.
The federal legislation emphasizes interprovincial economic integration and the streamlining of federal authorization processes.
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.
Taken together, the three bills with the number 5 in them illustrate a clear national direction:
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.
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