Ontario Announces Streamlined Permitting Process For Advanced Exploration And Mine Development Projects

On Friday, October 17, 2025, Ontario launched the One Project, One Process Framework ("1P1P Framework") aimed at streamlining the permitting, authorization and approval process for exploration and mine development projects in the province. This new framework will allow proponents to apply to have advanced exploration and mine development projects be designated such that the projects will be subject to an integrated approach to the permitting, authorization and approval processes.

The 1P1P Framework comes on the heels of the introduction of Ontario's trilogy of legislation seeking to fast-track and prioritize infrastructure, critical mineral, and other economy-building projects in the province (see our summaries of the Protect Ontario Through Free Trade Within Canada Act, 2025; the Protect Ontario by Unleashing our Economy Act, 2025 [Unleashing our Economy Act]; and the Protect Ontario by Building Faster and Smarter Act, 2025). The Unleashing our Economy Act amended multiple pieces of Ontario legislation, including the Mining Act and the Environmental Assessment Act, that govern the regulation of critical mineral and mining projects. These amendments, among other things, allow implementation frameworks like the 1P1P Framework to roll out.

Governments across Canada have also announced similar initiatives recently, including British Columbia's Infrastructure Projects Act (see our summary here) and the federal Building Canada Act (see our summary here).

Ontario says the 1P1P Framework will reduce government review timelines by half for designated mining projects through the coordination of provincial permitting, authorizations, and approvals processes required for those projects, as well as a clearer and more transparent pathway for consultation with Indigenous Nations. These measures are also intended to improve predictability for proponents and affected Indigenous Nations.

Proposed Project Designation

Proposed mining projects are eligible to be designated under section 153.0.1 of the Mining Act for application of the 1P1P Framework where a project:

• requires permits, authorizations, and approvals from more than one provincial ministry;
• would benefit from an integrated permitting, authorization, and approval process due to the project's impacts, complexity, or scale; and
• is one of the following types of projects:
  • new advanced exploration or mine production;
  • recommencement of a past-producing mine; or
  • a major mine expansion or modification to an existing advanced exploration or mine development project

(the "Eligibility Criteria").

The 1P1P Framework will not apply to early exploration activities or to federal or municipal regulatory approvals and permitting processes.

Ontario's Minister of Energy and Mines (the "Minister") may consider a project for designation where a proponent submits a request or where an Ontario ministry or Indigenous Nation refers the project to the Minister. In all cases, the proponent must prepare and submit a Project Definition, using the Project Definition Template, to begin the process.

When a proposed project is requested or referred for designation, the Ministry of Energy and Mines (the "Ministry"), with input from participating ministries, will assess the readiness of the project to advance (including the sufficiency of information provided in the Project Definition) and the alignment of the proposed project with the Eligibility Criteria. If needed, the Ministry, with support from participating ministries, will discuss with the proponent with project's eligibility and will seek additional relevant information needed by the Minister to inform a designation decision.

The Minister may designate a project where the Minister determines that the project meets the Eligibility Criteria. Notably, the completeness of the Project Definition is not an eligibility criterion. Rather, the Project Definition appears to be used as a tool to "support" the Minister's decision on whether to designate the project.

The framework strongly encourages proponents to request, prior to submitting their designation request or Project Definition, a preliminary meeting with the Ministry to receive guidance about the designation process and Project Definition. The Ministry is to hold such a meeting within ten business days of receiving a meeting request.

Responsibilities

Under the new process, designated mining projects will be managed by a "mine authorization and permitting delivery team" (the "Permitting Team") appointed by the Minister upon designation of the project. The Permitting Team is responsible for facilitating the coordination of all application, review, and decision-making processes for identified permits, authorizations, and approvals across participating ministries that have regulatory or mandate responsibilities in respect of designated projects. Currently, the following ministries are "participating ministries" under the 1P1P Framework:

• the Ministry of the Environment, Conservation and Parks;
• the Ministry of Natural Resources;
• the Ministry of Transportation; and
• the Ministry of Citizenship and Multiculturalism.

Ministries or agencies without direct permitting, authorization, approval, or other regulatory responsibilities for a designated project may also participate in the process for a designated project at the request of the Ministry, the proponent, an Indigenous Nation, a participating ministry, or the ministry or agency itself.

Participating ministries will carry out their permitting, authorization, approval, and associated Indigenous consultation processes in a coordinated and, where appropriate, parallel manner. Participating ministries will still carry out and retain responsibility for their statutory responsibilities, including the exercise of discretion in granting permits, authorizations and approvals and the fulfillment of the Crown's duty to consult and accommodate Indigenous Nations.

The Permitting Team is overseen by the Ministry, who will appoint a Team Lead to act as a single point of contact with other participating ministries, Indigenous Nations and the proponent.

The Permitting Team will provide coordination, guidance and support in attaining requisite provincial ministry permitting, authorization, and approval. However, the proponent remains responsible for applying for and discharging any applicable legislative and procedural requirements for such permits, authorizations and approvals. The proponent is also responsible for carrying out any delegated procedural aspects of consultation and covering its own project-specific costs associated with applications for permits, authorizations and approvals, including costs related to studies, meetings, and legal or professional advice. Proponents are required to actively participate in each stage of the 1P1P Framework, including responding to any requests for information or clarification and maintaining regular, proactive communication with their Team Lead.

British Columbia's Ministry of Mining and Critical Minerals also employs a coordinated approvals process for mining projects that is managed by the province's Major Mines Office (the "Coordinated Process"). The Major Mines Office manages all construction and operation permits issued under British Columbia's Mines Act for coal and mineral mines in British Columbia. Complex mining projects requiring permits under the Mines Act and other provincial regulatory schemes may be referred to the Coordinated Process. Like the 1P1P Framework, under the Coordinated Process, applications for provincial permits, authorizations and approvals related to a particular project are simultaneously reviewed and decided.

However, under the Coordinated Process, a mine review committee ("Review Committee") fulfils a similar but functionally distinct role than that of the Permitting Team under the 1P1P Framework. The Review Committee is comprised of technical reviewers from provincial ministries, Indigenous Nations potentially affected by the project, and the project lead from the Ministry of Mining and Critical Minerals. The Review Committee functions as more of an advisory committee to decision-makers than a project manager. The Review Committee's role begins once the project's applications have been submitted and the project is subject to the Coordinated Process. The Review Committee engages with the proponent in rounds of review of the project applications and ultimately prepares and reviews summary reports and draft permits that are submitted to the statutory decision-makers.

Framework Process

The 1P1P Framework document sets out the following process that will apply to permit application, review, consultation, and decision-making once a project is designated:

1. The Permitting Team will develop a project-specific Integrated Authorization and Permitting Plan ("IAPP") within 10 business days of confirming the completeness of the submitted Project Definition.

The IAPP sets out the steps and sequencing of the application, review, and decision-making processes for obtaining all the permits, authorizations and approvals the designated project requires.

2. Participating ministries will, within 30 business days of completion of the IAPP, identify Indigenous Nations whose Aboriginal and/or Treaty rights may be adversely affected by the designated project and associated permits, authorizations or approvals set out in the IAPP.

These identified Indigenous Nations will be notified by the Team Lead.

3. The Team Lead will issue a direction letter to the proponent requiring it to prepare and submit a Plan for Consultation.
4. The proponent will prepare and submit a Plan for Consultation in coordination with their Team Lead and Permitting Team.

The Plan for Consultation will describe how the proponent proposes to carry out the delegated procedural aspects of consultation for each permit, authorization and approval specified in the IAPP. The proponent must also prepare and provide an interim consultation report to the Permitting Team on a quarterly basis.

5. The Permitting Team will prepare an Integrated Consultation Plan ("ICP") within 15 business days of the submission and its acceptance of the Plan for Consultation.

The ICP will outline how the Ontario Crown intends to carry out its role in fulfilling the duty to consult across all permits, authorizations and approvals in the IAPP. The ICP will "consolidate" consultation requirements from all participating ministries and seek to align the consultation process to reduce duplication of Crown engagements.

6. Upon finalization of the IAPP, Plan for Consultation, and ICP, the proponent will submit applications for permits, authorizations and approvals specified in the IAPP directly to each participating ministry.
   1. The Team Lead will organize monthly meetings with the proponent (and Indigenous Nations and other participating ministries, as needed) to monitor progress, address issues, and provide updates on permitting and duty to consult and accommodate activities.

The 1P1P Framework and work of the Permitting Team will conclude once decisions respecting permits, authorizations or approvals specified in the IAPP have been made.

It is important to note, however, that the 1P1P Framework also provides that a Permitting Team's activities in respect of a particular project may be suspended, either at the request of the proponent or due to other factors such as insufficient technical studies, limited Indigenous consultation efforts by the proponent, or low commodity prices. This "stop the clock" mechanism is common in other regulatory processes. In other circumstances, (which include where a project is placed in a state of inactivity), the Minister may revoke a project's 1P1P Framework designation and the respective Permitting Team would be discontinued altogether.

Consultation with Indigenous Nations

Neither the 1P1P Framework, nor Ontario's trilogy of permit streamlining legislation, changes the need for consultation and accommodation with Indigenous Nations.

The 1P1P Framework aims to fully uphold the Crown's duty to consult and to reduce the burden engagement activities can place on Indigenous Nations, by "coordinating" consultation efforts among participating ministries on a project-by-project basis rather than a permit-by-permit basis. However, each statutory decision-maker at participating ministries/agencies is to continue making decisions on applications independently based on their legislative mandates and technical requirements. Decision-makers are also to retain discretion to determine whether the duty to consult has been satisfied with respect to their permitting, authorization or approval process. It is made explicit in the 1P1P Framework that alignment of consultation timelines with permitting activities is intended "solely for planning purposes" to support coordination amongst participating ministries, proponents and Indigenous Nations. Ontario is to provide sufficient time for consultation to occur and to demonstrate flexibility as changes or updates occur to the timeline or structure occur to allow consultation to be meaningful and responsive to Indigenous Nations' needs.

The 1P1P Framework contemplates delegation of certain procedural aspects of the duty to consult and accommodate. Where delegation to the proponent is to occur under the 1P1P Framework, the Team Lead will issue a direction letter to the proponent that confirms the list of Indigenous Nations owed a duty to consult and that sets out the delegated aspects of consultation. Indigenous Nations will also receive notification letters where procedural aspects are delegated. Proponents are responsible under the framework for carrying out their delegated aspects.

Participating ministries, through the Permitting Team, will identify Indigenous Nations who are owed a duty to consult and accommodate as well as interested Indigenous Nations for whom the duty is not triggered. Indigenous Nations owed a duty to consult and accommodate will be notified. It is not clear from the 1P1P Framework if it will mandate a particular process to be followed where an Indigenous Nation disagrees with the determination of whether they are owed the duty to consult and accommodate.

The Team Lead will serve as Ontario's primary contact point for Indigenous Nations in the consultation process. Project timelines and other relevant project information will be shared with identified Indigenous Nations and consultation sessions will, where appropriate, be coordinated across participating ministries to address multiple permitting, authorization or approval requirements.

Funding support for consultation will be available through the Indigenous Participation Fund and other sources, including the proponent.

Potential Implications

The 1P1P Framework presents both opportunities and new considerations for proponents. While it remains to be seen whether timelines will indeed be shortened, there, nonetheless, is significant value in ministries coordinating regulatory and permitting processes. Proponents who understand application requirements and submit a robust application package, inclusive of the necessary supporting studies, and combine it with early engagement with impacted Indigenous communities will likely realize the objectives of the framework.

In addition, by coordinating approvals across multiple ministries and setting clear service standards, the framework could support earlier engagement with lenders and investors and may ultimately improve bankability for projects.

Lenders will continue to require evidence that key permits and Indigenous consultation obligations are complete before financial close. Financing documents will likely treat finalization of the IAPP — and the project's formal designation and continued maintenance under the 1P1P Framework — as conditions precedent to funding where such accelerated scheduling is modelled as part of a given project.

Where an Indigenous Nation participates by investing in a project designated under the 1P1P Framework, the project itself may also benefit from access to complementary provincial programs, such as the Indigenous Opportunities Financing Program. Where applicable, early integration of these funding streams into the capital structure will be key to optimizing cost of capital. Such equity participation continues to be rare in the mining sector directly (as opposed to supporting infrastructure) due to the risk profile of mining projects.

Next Steps

As of October 17, 2025, proponents can apply to have their Ontario-based advanced exploration and mine development projects designated under the 1P1P Framework.

McMillan's Mining and Regulatory groups will continue to monitor implementation of and amendments to the 1P1P Framework. To discuss the potential opportunities and implications of the new permitting framework, or for further information and guidance on how to apply to have your project designated under the 1P1P Framework or other coordinated permitting structures, please contact the authors or a member of our Mining or Regulatory groups.

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