As it has done or is seeking to do with other provinces, the federal government recently signed a cooperation agreement with Ontario to streamline and expedite project assessment processes. The purpose of these agreements is to minimize duplication between provincial and federal impact assessments and outline the respective roles and responsibilities of each government, including when and under what circumstances each government will lead a project’s assessment.
Projects in Canada often face extensive regulatory requirements and assessment obligations at multiple levels. A key challenge has been the overlapping responsibilities for environmental protection shared by federal and provincial governments. The Supreme Court of Canada’s 2023 decision in Reference re Impact Assessment Act explored these issues, referring to concerns raised by provinces, Indigenous groups and industry over the federal regime’s unnecessary duplication and lack of federal-provincial coordination1.
In response to the Supreme Court’s decision, Canada amended the federal Impact Assessment Act in 2024 to better align with the government’s commitment to achieve “one project, one assessment”. The mandate of the IAA now provides that Canada, the Minister of the Environment (the Minister), the Impact Assessment Agency (the Agency) and federal authorities, in administering the IAA, “must exercise their powers in a manner that … promotes cooperation among jurisdictions”2.
The following IAA sections shape how federal and provincial processes interact, enabling Canada to develop and enter into cooperation agreements:
Against this regulatory backdrop, cooperation agreements specify, among other things, when a single harmonized process incorporating both provincial and federal expertise may be used, and when full substitution (of the federal process by the provincial process) will instead occur. Rather than undergoing two separate reviews, the province can, under substitution, lead a single process on behalf of both governments, using its own procedures and timelines. Based on BC’s experience with its cooperation agreement, the result has been a reduced regulatory burden, elimination of duplicative assessments, and expedited timelines (compared to a two-assessment scenario).
The federal government highlighted cooperation agreements as a key tool to realize its “one project, one review” goal in the May 2025 Speech from the Throne. During the Speech, the government committed to reaching cooperation agreements with each interested province and territory within six months. Budget 2025 reinforced this priority, emphasizing the use of cooperation agreements to accelerate assessments for projects of national interest and to “signal to investors that Canada’s federal, provincial, and territorial governments are committed to working together to enable development, while protecting Indigenous rights and the environment”3.
To date, there are five cooperation agreements under the IAA, either finalized or in draft form. The agreements set out how the respective governments will work with the federal government to coordinate project assessment and regulation. The recitals affirm each parties’ jurisdiction, commitment to engaging in meaningful consultation with Indigenous Peoples, and the principles of transparency, efficiency and timeliness.
Signed in September 2019, the BC agreement was, until recently, the country’s only finalized and executed cooperation agreement4. Under this framework, several project assessments have proceeded by way of substitution, allowing the BC Environmental Assessment Office to conduct the assessment process under provincial assessment laws5. Two of those projects were approved under the IAA: the Ksi Lisims LNG - Natural Gas Liquefaction and Marine Terminal Project6 and the Cedar LNG Project7. Canada has noted that the Cedar LNG Project was completed in just 3.5 years8.
Ontario finalized its cooperation agreement on December 18, 2025, with only minimal changes from the draft announced on November 19, 2025. The New Brunswick cooperation agreement was announced on September 19, 2025, and finalized on December 16, 2025. Interestingly, the finalized version includes a new recital affirming the goal of more expeditious assessments, with New Brunswick supporting “Canada’s commitment to ensure all federal assessment decisions are rendered within two years”.
The draft Manitoba agreement was published on November 19, 2025, while the draft PEI agreement was published on November 3, 2025.
As the Ontario and other cooperation agreements come into force, they provide the potential to significantly reduce regulatory burden and expedite projects. How they will be implemented in practice will be key.
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