On June 20, 2025, the federal government passed Bill C-5: An Act to Enact the Free Trade and Labour Mobility in Canada Act and the Building Canada Act, commonly referred to as the One Canadian Economy Act (the Act). Aimed at promoting interprovincial trade and facilitating the approval of major infrastructure projects, the Act has received considerable support from first ministers and has generally fostered national alignment in response to concerns over US tariffs.
The Act relies on two main legislative elements:
- The Free Trade and Labour Mobility in Canada Act (the FTLMA), which establishes a framework to minimize interprovincial trade barriers of goods and services and to improve labour mobility across Canada.
- The Building Canada Act (the BCA), which creates an accelerated process for infrastructure projects that are of national interest.
The Free Trade and Labour Mobility in Canada Act
The FTLMA mandates that goods, services and workers should be able to move freely across provincial borders, subject to minimal restrictions.
With regards to goods and services, the FTLMA introduces a single-jurisdiction review: any good or service that meets applicable provincial standards will be automatically deemed federally compliant. The federal government will not impose additional requirements where provincial standards are considered comparable; in such cases, provincial compliance will be accepted at the federal level. This approach will enhance internal economic mobility and allow Canada to function as a single market where Canadian businesses can easily sell their products across the country. Regarding labour mobility, the FTLMA provides a framework that enables federal regulatory bodies to easily recognize provincial licenses and certifications, facilitating worker mobility across provinces.
The objective of the FTLMA is to establish a national system where a good, service or work licence that meets the requirements of one jurisdiction is recognized as meeting the requirements of all jurisdictions. While the FTLMA introduces federal initiatives to minimize trade barriers, the federal government's efforts require further reinforcement; the provinces will also have to play a role in eliminating existing trade barriers. Many provinces have ratified legislation to align provincial legislation with the national trade and labour mobility objectives: Québec's Bill 112, Nova Scotia's Bill 36 and British Columbia's Bill 7.
The Building Canada Act
The BCA aims to support Canada's economy by streamlining federal approvals for major projects with the objective of reducing the federal approval timeline from five years to two. It seeks to provide project proponents with early federal approval, thus reducing the likelihood of last-minute rejections, while still requiring full review and compliance with applicable federal authorizations. The BCAincludes a sunset clause which stipulates that five years after it comes into force, no new projects will be eligible for the accelerated timeline regime unless such regime is renewed through further legislative action.
The BCA creates a new Federal Major Projects Office and appoints a single federal minister (the Minister) to oversee its initiatives. By providing project proponents with one centralized federal point of contact, the structure is expected to significantly reduce delays that often arise from the need to coordinate with multiple federal departments.
As part of this federal approval process, projects will first be identified by the Minister as National Interest Projects (a NIP) based on the following list of non-exhaustive factors:
- Strengthen Canada's autonomy, resilience and security;
- Provide economic or other benefits to Canada;
- Have a high likelihood of successful execution;
- Advance the interests of Indigenous peoples; and
- Contribute to clean growth and to meeting Canada's objectives with respect to climate change.
The NIP regime will cover major initiatives in sectors like energy, mining and transportation, such as the development of ports, mines, renewable energy installations and pipeline construction.
Once designated as a NIP, the federal government will issue an early approval, operating on the premise that the project is deemed authorized. This approach shifts the process from a question of "whether" the project will be approved, to one of "how," effectively ensuring authorization will be granted as long as the necessary conditions are subsequently met.
Following the early approval, the Minister will provide an all-authorizations-in-one document. This document will be issued once (i) the NIP proponent has fulfilled all relevant federal requirements, (ii) the Minister has consulted each relevant minister regarding approval conditions, and (iii) Indigenous peoples have been consulted regarding potential unfavourable effects. This procedure seeks to reduce delays and back-and-forth communication, while providing NIP proponents with a single federal contact point.
The BCA also acknowledges that many NIPs may fall under the Impact Assessment Act (IAA), which sets out the process for evaluating the environmental and socio-economic impacts of major projects, aiming to prevent or mitigate significant adverse effects before they occur. The IAA process begins with a planning phase, during which the project proponent defines the scope of the project and identifies potential concerns. This is followed by a more detailed impact assessment phase. While the IAA process would still apply, the BCA introduces one key change: it eliminates the standard 180-day planning phase.
Conclusion
The One Canadian Economy Act will work towards unifying Canada's landscape by seeking to pursue the dismantling of interprovincial trade barriers and promoting faster government approvals for projects of national interest. While it lays the foundation for a unified internal market and streamlined project approvals, its success will depend on the cooperation from provinces and effective implementation.
Should you have any questions about the Act or other issues related to public infrastructure, please do not hesitate to contact Lampros Stougiannos, Anoosh Loertscher or any member of Dentons'1. The authors would like to thank Nicolas Tawfik, Dentons summer student in Montréal, for his contributions to this insight.
Footnote
1. The authors of this insight are Lampros Stougiannos and Anoosh Loertscher. Lampros Stougiannos is a partner in Dentons' Infrastructure and Public-Private Partnership group based in Ottawa. Anoosh Loertscher, an associate in the same group, is based in Montréal.
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