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Background
On August 29, 2025, Prime Minister Mark Carney launched the Major Projects Office (MPO) under the federal Building Canada Act (Act).
Readers will recall that the Act was introduced as part of Bill C-5, the One Canadian Economy Act, which received Royal Assent on June 26.
Significantly, the Act empowers the Minister to initiate a process to add major projects in the national interest of Canada to Schedule 1 to the Act, triggering the issuance of a single authorizing document that replaces most existing federal permits and consolidates conditions. The Act includes a 5-year sunset clause, meaning designations must be made by mid-2030. For more background on the Act please see our bulletin here.
Together, the Act and the establishment of the MPO represent a transformative reform to federal infrastructure policy — a centralized "one-window" approach that replaces multi-year, multi-agency delays. These developments also align with Canada's broader ambition to become a resilient and competitive economy — particularly in critical minerals, energy, transportation, clean infrastructure, and Indigenous-led developments.
MPO's Mandate & Functions
The MPO is headquartered in Calgary, with satellite offices across Canada. Dawn Farrell, a veteran CEO and board member with major energy companies, has been named as the first CEO of the MPO. Both the location of the headquarters and appointment of an energy executive arguably signals the federal government's interest in greater collaboration and ensuring that Canada is best positioned to be more economically competitive on the international stage, both via the development of domestic projects as well projects which will foster greater export opportunities for Canadian products being produced across the country.
The MPO's principal mandate and function is to streamline regulatory approvals under a "One Project – One Review" model for projects designated as being in Canada's national interest. Timelines are being shortened to a maximum of two years, in contrast to prior 5‑year or longer approval periods, often with delays.
Significantly, the MPO will not only be responsible for streamlining the approvals process for projects added to Schedule 1 of the Act – it will also be the office responsible for review and assessment of all projects seeking to achieve Schedule 1 designation. As such, proponents of projects seeking to utilize the Act's streamlined processes will engage with the MPO at a very early stage, and should become familiar with its processes at the earliest possible juncture.
Projects not designated for inclusion on Schedule 1 continue under the standard, often longer, multi-agency federal approval regime.
An Indigenous Advisory Council (representing First Nations, Inuit, Métis, and modern treaty partners) will be established to advise the MPO; members are to be announced shortly. While Indigenous consultation is mandatory at every stage, equity participation opportunities are also expected to be actively promoted.
Of interest from a financing standpoint, the Prime Minister's release of August 29 states that the MPO will also "work to attract domestic and global capital" to Schedule 1 major projects, and "will help structure and co-ordinate financing from the private sector, provincial and territorial partners, and government initiatives, including the Canada Infrastructure Bank, the Canada Growth Fund, and the Indigenous Loan Guarantee Program".
Stakeholders will be watching closely for further details on how the MPO will be equipped with the resources necessary to carry out its substantial responsibilities.
Designation Process for Projects of National Interest
Under the Act, the following seven-step process applies once a project is proposed:
Project Submission – Proponents (including Indigenous communities, provinces, municipalities, etc.) submit project information to the MPO.
Initial Review – MPO assesses the project against criteria such as national resilience/security, economic benefit, likelihood of completion, Indigenous benefits, and climate/energy transition goals; identifies required federal approvals.
Consultations – Ongoing early engagement with Indigenous Peoples, provinces/territories, and relevant federal Ministers.
Minister's Recommendation – The responsible Minister recommends listing the project in Schedule 1 of the Act to the Governor in Council.
30-Day Public Notice – A Canada Gazette Part I notice is published. Provinces/territories provide written consent if the project concerns their exclusive jurisdiction.
Governor in Council Decision & Order in Council – At this stage, the project is officially added to Schedule 1 of the Act; a summary is to be posted in an online registry.
Upfront Greenlight – Following Schedule 1 inclusion, the MPO consolidates all federal approval conditions into a single "conditions document." The approval focus now shifts to how the project proceeds (not if), with consultations continuing throughout, and proponents expected to reach completion within two years.
Implications for Industry Participants
With the establishment of the MPO, project proponents (including the private sector, Indigenous Peoples, provinces, territories and municipalities) have the opportunity to accelerate the development of large-scale proposals (e.g. infrastructure, energy, critical minerals, clean tech, transportation, ports) that align with national resilience, economic development, Indigenous partnerships, or net-zero transition.
To take advantage of this accelerated path, industry participants should:
- Consider initiating the MPO intake process at the earliest realistic time. Early engagement with the MPO provides an opportunity to streamline permitting, access blended finance, and position projects as matters of national interest ahead of the 5-year sunset clause.
- Review and become familiar with the MPO intake form, now available online for this purpose at https://forms-formulaires.alpha.canada.ca/en/id/cmevsgqif004hyc01ng0i7adg.
- Where projects are strong candidates for Schedule 1 inclusion, clearly budget for accelerated timelines available under the Act, as all internal processes, financing strategies, stakeholder management and any required provincial/territorial or municipal approvals must also align with a 24-month regulatory window.
- Initiate early dialogue with Indigenous stakeholders and assess opportunities for Indigenous equity, together with readiness to comply with one-window environmental/regulatory review.
- Monitor publications (Canada Gazette, forthcoming MPO registry) for incoming Schedule 1 listings, and consider staging adjacent or related projects accordingly.
- Prepare for increased transparency and accountability for listed projects, given that designated projects will be listed publicly in the Canada Gazette and in the upcoming MPO registry, ensuring visibility and scrutiny.
- Consider blended public/private financing structures, given the MPO's stated role in financing coordination and aligning support from federal funding programs and institutions, as well as with provinces/territories and other local government participation.
Conclusion
The Act's designation process promises to transform how major projects navigate federal approvals in Canada, and the establishment of the MPO is a critical first step in realizing the Act's goals. For further information on how the new legislation may affect your business, or to connect with us to explore how your projects can best leverage the MPO's streamlined approach, please contact please contact Catherine Doyle, Sharon G.K Singh or Melissa Stoesser Young.
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
