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On October 27, 2025, Premier of Ontario Doug Ford and Attorney General Doug Downey announced the government's intention to amend provincial election laws under the Election Act and Election Finances Act, citing the need to "strengthen and increase public trust in the province's electoral system".1 If introduced, this legislation would mark the third time in four years that the Ford government has sought to overhaul Ontario's election laws, having previously done so in 2021 through the Protecting Ontario Elections Act and the Protecting Elections and Defending Democracy Act.2
This election law update is intended as general guidance only. If you have specific questions or concerns, please contact us. We would be pleased to assist you.
The key proposed reforms
1. Eliminating fixed election dates
Provincial general elections are currently scheduled to take place on the first Thursday in June in the fourth calendar year following polling day in the most recent general election.3 The proposed legislation, if introduced, would eliminate fixed election dates, reverting to the constitutional default that elections must be held at least once every five years.
Although the proposed changes impact election timing, the discretionary power of the Premier to ask the Lieutenant Governor to call an early election remains the same.
When fixed election dates were first proposed by the government of then-Premier Dalton McGuinty in 2004, they were promoted as a way of removing political considerations from the timing of elections.4 However, because the Premier still retained the ability to call an early election, the fixed date election reform did not entirely remove political considerations from the timing of elections.
2. Eliminating pre-writ spending limits for third parties and political parties
In light of successful legal challenges regarding the constitutionality of the Ontario government's 2021 amendments to third party spending rules,5 the government proposes to eliminate pre-writ spending limits for third parties and political parties altogether. The government's new release states that these limits were originally introduced to curb political spending in the lead-up to a fixed election date. Ostensibly, pre-writ spending is no longer a concern if fixed election dates are eliminated.
3. Increasing financial penalties for non-compliance with the Election Finances Act
The Ontario government intends to introduce new financial penalties for non-compliance with the Election Finances Act, including for failing to provide information to the Chief Electoral Officer and not complying with political advertising rules.
Specifically, the government proposes to increase the maximum penalty for third parties who exceed the statutory political advertising spending limit. Currently, the maximum is set at $10,000 for individuals and $100,000 for corporations or other entities.6
The government also proposes raising the penalty for third parties that fail to register with Elections Ontario. The current maximum penalty is $10,000.7
4. Expanding the Chief Electoral Officer's investigative powers
In response to recommendations from Ontario's Chief Electoral Officer, the government announced it will introduce amendments to provide that officer with "new tools" to ensure that third parties abide by political advertising rules, including the authority to make information requests from registered and unregistered entities.
5. Enhanced third party disclosure to broadcasters and publishers
In the 2021 amendments to the Election Finances Act, the Ontario government created a framework requiring third parties to submit interim reports to the Chief Electoral Officer.8 A third party must file an interim report each time it spends or commits to spend on political advertising, with a separate report being required for each time its aggregate spending increases by at least $1,000. It must also report when it reaches the legal spending limit. The government proposes to expand this framework to require third parties to provide proof of registration status to broadcasters and publishers before advertisements are placed during the election period.
6. Increasing the threshold on personal contributions to a political party
The government proposes to increase the limit on personal contributions to a political party from $3,400 to $5,000, starting in 2026. Increases in the future are to be indexed to the rate of inflation. This increase, if introduced, would be consistent with, or lower than, the maximum allowable amount in other provinces, including Alberta, Manitoba, and Nova Scotia.
7. Quarterly per vote subsidy
On the advice of the Chief Electoral Officer, the Ontario government intends to make the quarterly per-vote subsidy that eligible political parties currently receive permanent.
8. No proposed changes to the electoral map
While the government has proposed significant electoral reforms, there are no plans to change Ontario's provincial riding map, which has remained unchanged since 2015, even though there has been a significant overhaul of the electoral map at the federal level.
The bottom line
The Ford government's proposed electoral reforms, if introduced, would shift the timing, financing, and regulation of provincial elections. Notably, the government has not signalled any changes to the municipal election framework.
We will continue to monitor this situation, and any legislation that may be introduced. Given the specificity of the government's recent announcement, we anticipate the introduction of any legislation to be imminent.
Footnotes
1 Ministry of the Attorney General of Ontario, News Release, "Ontario Strengthening Provincial and Electoral Processes" (27 October 2025), online: Ontario Newsroom <https://news.ontario.ca/en/release/1006654/ontario-strengthening-provincial-electoral-processes>.
2 Bill 254, Protecting Ontario Elections Act, 1st Sess, 42nd Leg, Ontario, 2021 (assented to 19 April 2021), S.O. 2021, c. 5 [Protecting Ontario Elections Act]; Bill 307, Protecting Elections and Defending Democracy Act, 1st Sess, 42nd Leg, Ontario, 2021 (assented to June 14, 2021),S.O. 2021, c. 31.
3 Election Act, R.S.O. 1990, c. E.6, at s. 9(2).
4 Office of the Premier of Ontario, Backgrounder, "McGuinty Government To Strengthen Democracy With Fixed Election Dates" (01 June 2004), online: Ontario Newsroom <https://news.ontario.ca/en/backgrounder/4292/mcguinty-government-to-strengthen-democracy-with-fixed-election-dates>.
5 Ontario (Attorney General) v. Working Families Coalition (Canada) Inc., 2023 ONCA 139, aff'd 2025 SCC 5.
6 Election Finances Act, at s. 45.1(5)(2).
7 Election Finances Act, at s. 45.1(5)(3).
8 Protecting Ontario Elections Act, at s. 16; Election Finances Act, at s. 37.10.2.
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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
