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In welcome news to infrastructure industry participants, Ontario's 2025 Fall Economic Statement (the Statement), tabled by Finance Minister Peter Bethlenfalvy, reaffirms the provincial government's commitment to its $201 billion, 10-year capital plan originally set out in its 2025 budget (Budget 2025). For more background on the announcements in Budget 2025, see our bulletin here.
While the Statement contains few new programs or funding initiatives, it provides some meaningful updates to major energy, transit, transportation, and housing-enabling infrastructure projects currently underway or in the planning stage. Some of the most notable items include:
- Continued advancement of large-scale development at the Bruce and Wesleyville nuclear sites.
- Construction commencing on the first of four Small Modular Reactors ("SMRs") at the Darlington nuclear site.
- Broadening of Building Ontario Fund's ("BOF") mandate to include critical minerals as a priority sector and exploring adding new priority sectors to the Indigenous Opportunities Financing Program ("IOFP").
- Continuing transit, regional rail, and highway programs, with major procurements and groundbreaking underway.
- Progress on streamlining approval timelines through One Project, One Process; Special Economic Zones, and centralized digital permitting initiatives.
Taken together, these initiatives suggest a robust pipeline for contractors, lenders, investors, and project sponsors. Further details on major elements follow below.
Critical Minerals and the Ring of Fire
The Statement reiterates the government's commitment to investing in a made-in-Ontario critical minerals supply chain. Initiatives announced in Budget 2025 include $500 million for the Critical Minerals Processing Fund, all-season road projects connecting the Ring of Fire region, and the launch of the "One Project, One Review" framework that aims to cut review times in half for exploration and mine development projects. These initiatives, especially if progress with the respective Indigenous communities on addressing their priorities continues to be made, could mean a more streamlined permitting and review process for project owners, more willingness from financing partners to invest, and an increase in project activity in the sector. Some notable projects and initiatives from the Statement are outlined below.
As announced in September, the government is investing $61.8 million in critical road infrastructure in Greenstone that will be the gateway to the Ring of Fire. The project will fortify connections between Highway 11 in the south to Highway 584 in the north and the Trans-Canada Highway. The government is also working with First Nations to advance other all-season road projects, which it views as critical to unlocking opportunities in the Ring of Fire region.
Ontario's Critical Minerals Processing Fund aims to provide strategic support for projects that will accelerate Ontario's critical minerals processing capacity. Although announced in Budget 2025, there were no new details on the launch of the fund disclosed in the Statement.
As highlighted in the Statement and as previously detailed in our bulletin here, the previously announced "One Project, One Process" framework establishes a single, coordinated approvals track for advanced exploration and mine development, aiming to cut review times by at least 50% while maintaining environmental standards and Indigenous consultation. These reforms offer the potential for faster timelines for mining and resource projects, provided that all environmental safeguards and consultation obligations are maintained or carried out.
Building Ontario Fund
Following an additional $5 billion in funding announced in Budget 2025, the Statement provides that a new area of focus, critical minerals, has been added to the Building Ontario Fund's (BOF) priority sectors.
The IOFP has completed the transition to being overseen by the BOF, following an increase to the fund's envelope from $1 billion to $3 billion announced in Budget 2025. The Statement notes that the BOF will begin engaging First Nations, Métis, and Inuit communities, as well as infrastructure financing experts, on the addition of new priority sectors to the IOFP. Potential expansion could include electricity, critical minerals, and resource development.
Up to $1 billion in funding from the BOF will support an equity investment in the Darlington New Nuclear Project, which the federal government referred to the Major Projects Office (MPO) for consideration under the Building Canada Act. The government and Ontario Power Generation (OPG) are also pursuing opportunities for equity partnership with Williams Treaties First Nations, which would be the first of its kind for nuclear energy generation in Canada.
Transit Infrastructure
Budget 2025 laid out a $61 billion, 10-year plan to upgrade transit infrastructure across the province, focusing on subway, light rail transit (LRT), and regional rail. The Statement elaborates on these initiatives as follows:
Subways and LRT Expansion
- Proposed Sheppard Subway Extension: planning and consultation is advancing on a potential rapid transit extension both east and west of the existing TTC line 4.
- Works are underway on the Yonge North Subway Extension and Hamilton LRT.
Regional Rail
- The government highlights that it has proposed the GO 2.0 expansion to the MPO for consideration.
- Kitchener GO Extension: an agreement in principle has been reached with CN Rail to purchase land for dedicated GO tracks on the Kitchener Line.
- Northlander Restoration: contracts for stations and bypasses have been awarded.
Green Bond Financing
- In August of this year, the province issued $1 billion in Green Bonds to fund major transit projects including the Ontario Line, Scarborough Extension, Hazel McCallion Line, and GO Transit expansion.
Highway, Road, and Bridges
Budget 2025 announced nearly $30 billion over ten years to support a comprehensive highway, road, and bridge infrastructure program. The statement only provides a few major updates on continuing projects such as Highway 413, the Bradford Bypass, and the Queen Elizabeth Way Garden City Skyway Twinning.
The previously announced feasibility study for a new vehicle and transit tunnel expressway under Highway 401 is now underway. Notably, the Statement also highlights that the government has included this project as a proposal to the MPO.
Housing-Enabling Infrastructure
In August of this year, the government announced an additional $1.6 billion to accelerate construction of housing and housing-enabling infrastructure, nearly doubling the Municipal Housing Infrastructure Program's (MHIP) funding to $4 billion. Additionally, municipalities can access up to $1 billion in loans through the Infrastructure Ontario Housing-Enabling Water Infrastructure stream.
Healthcare
Budget 2025 dedicated $56 billion over 10-years for health infrastructure projects. The Statement provides an update on a number of projects that are currently underway, including the Timmins and District Hospital Emergency Department expansion, St. Francis Memorial Hospital Emergency Department redevelopment, Ottawa Hospital Civic Campus Redevelopment; the new Windsor-Essex Regional Hospital; and the Trillium Health Partners redevelopment project at the Mississauga Hospital site.
Long-Term Care
In August 2025 the government announced the new Long-Term Care Home Capital Funding Program aimed at increasing funding to stimulate more construction starts of long-term care homes. The new funding model moves from a fixed cost-per-bed approach to now providing up to 85% ministry funding for eligible expenditures. These changes may serve to provide increased certainty to operators and financing parties.
Education
Budget 2025 dedicated $30 billion over 10-years for school and childcare development, including $23 billion in capital grants. The Statement highlights twelve projects currently underway for either new schools or additions to existing facilities. As part of the funding commitment announced in Budget 2025, the Statement also notes that approximately $2 billion has been made available for the 2025-26 school year to repair and maintain schools.
Electricity and Renewables
In June 2025 the government announced an integrated energy plan called Energy for Generations, which brings electricity, natural gas, hydrogen, and other energy sources under a single provincial strategy. Some updates on projects undertaken as part of this strategy are highlighted below.
New Nuclear Power Capacity
The government is progressing to early-stage planning for new large-scale nuclear energy projects at the Bruce nuclear site and OPG's Wesleyville site in Port Hope. Following project approval announced in Budget 2025, construction has also begun on the first of four Small Modular Reactors (SMRs) at the Darlington nuclear site, the first of their kind among G7 nations. The Statement notes that the government is also considering OPG's plan to proceed with refurbishing four units at the Pickering nuclear station and supporting the refurbishment of units at the Darlington and Bruce stations.
Hydrogen Power Update
In March 2025 the government announced a new $30 million round of the Hydrogen Innovation Fund to support the integration of low-carbon hydrogen into the electricity grid and support the broader use of hydrogen in transportation and heavy industry. The Statement confirms that the Independent Electricity System Operator (IESO) will provide recommendations for a hydrogen interruptible rate pilot that could offer hydrogen producers discounted electricity rates in exchange for reducing consumption during peak demand period. The government is also exploring options to regulate hydrogen pipelines.
Electricity Transmission Expansion
The Statement provides an update on transmission expansion projects. These include two new transmission lines from Bowmanville to the GTA and from Windsor to Lakeshore. The province is also upgrading two major lines between Orangeville and Barrie, and between Manby and Riverside Junction in Toronto. Other projects include multiple 230-500kV builds or upgrades, with timelines through 2029-2030. The government is also working with the City of Toronto to bring a third transmission line into downtown Toronto.
Permitting and Approval Regimes
Special Economic Zones
As we discussed in a previous bulletin, the Special Economic Zones Act enables expedited approvals for strategically important projects taking place within Special Economic Zones (SEZs). Once implemented, the SEZ regime could create a streamlined development and permitting process for Designated Projects and Trusted Proponents. The Statement suggests the government aims to finalize the regulations by the end of the year.
Centralized Permitting and Red Tape Reduction
In October of this year, the government introduced the Building a More Competitive Economy Act and related initiatives. Of most interest to industry participants is the proposal to develop a centralized digital permitting system that streamlines how businesses apply for and monitor permits.
Federal Government's Role
The Statement makes a number of calls for enhanced federal participation to advance Ontario's infrastructure priorities, with a focus on development of the Ring of Fire region. The province asks the federal government to streamline its own permitting and assessment processes and calls for funds that match or exceed Ontario's $1-billion commitment toward infrastructure development in the region.
The Statement also focuses on clean energy and intercity rail by calling on the federal government to implement and expand all outstanding clean-economy investment tax credits and to provide funding to help deliver new passenger rail service for the Greater Golden Horseshoe area.
Taken together, these requests reflect a broader expectation that Ottawa will play an active role in both regulatory alignment and capital mobilization to accelerate major infrastructure delivery.
Takeaways for Project Stakeholders
The Ontario government continues to signal that infrastructure delivery is a core economic priority and that sustained capital investment is supported by relatively stable fiscal conditions. At the same time, the scale of the capital plan will likely require support from other levels of government as well as broad private sector and Indigenous participation and partnerships. There also appears to be broad alignment between provincial and federal priorities which, if it can lead to shared alignment and vision on financial support, execution, and timing, may lead to a greater likelihood of success in realizing the Statement's vision.
The foregoing provides only an overview and does not constitute legal advice. Readers are cautioned against making any decisions based on this material alone. Rather, specific legal advice should be obtained.
© McMillan LLP 2025