Permit me to explain: Bill C-39’s plan to build Canada faster

“Canada is a country of high standards, but high standards do not require slow decisions.” — Prime Minister Mark Carney

On September 21, 2026, the Government of Canada introduced Bill C-39, the Building Canada Strong Act. The Bill outlines Canada’s plan to streamline Federal approval processes, modernize labour relations while protecting workers and advance environmental sustainability and Indigenous reconciliation.

According to the Government, the Bill is the product of significant groundwork already underway. Since 2025, 27 nation-building initiatives representing approximately $200 billion have been referred to the Major Projects Office established under the Building Canada Act of 2025. The Bill is said to incorporate more than 26,000 consultation responses and 78 engagement sessions undertaken with regard to the 2025 BCA. In addition to the measures included in the Bill, the Government indicated that hiring 100 new health and safety officers (an approximately 70% increase in inspection capacity) and 26 new staff at the Canada Industrial Relations Board will be required to clear complaint backlogs and crack down on worker misclassification.

The Bill comprises three Parts:

1. Part 1: Build Canada Now
2. Part 2: Keep Canada Moving
3. Part 3: Canada Strong for All.

Part 1: Build Canada Now

Part 1 is focused on streamlining project approvals across the country. According to the Government, the current approvals process takes a minimum of five years. The Bill proposes establishing a one-year timeline for Federal reviews and decisions from the time a proponent submits a comprehensive application. Additionally, timelines for approvals regarding small and medium projects submitted to the Canada Energy Regulator and the Canadian Nuclear Safety Commission are expected to be reduced to six months.

The mechanisms for accomplishing these timelines include:

• Implementing a “one project, one decision” approach – Whereby the Minister of Environment would issue a single approval document consolidating all required permits. The current process requires multiple decisions to be coordinated across multiple departments.
• Assigning a single project assessor for certain categories of projects – For example, the Canada Energy Regulator would review pipelines, transmission lines, and some offshore renewable projects, while the Canadian Nuclear Safety Commission would review nuclear and uranium projects.
• Creating a “Crown Consultation Hub” – A hub would be created within the Impact Assessment Agency to coordinate Federal consultation with Indigenous groups.
• Creating regions of national interest – Following a regional impact assessment, a region could receive the “national interest” designation, which would enable developments to be pre-approved, subject to conditions. Projects within these designated regions would receive the same treatment as projects of national interest.
• Legislative and permitting amendments – The Bill would amend the Impact Assessment Act, Building Canada Act, Species at Risk Act, Canadian Navigable Waters Act, Fisheries Act and disposal at sea permitting regimes to modernize processes, reduce duplication and move projects from application to construction more quickly. It is worth noting that the Government had earlier abandoned plans to exempt certain projects from laws designed to protect species at risk after receiving an overwhelmingly negative response during consultation sessions.
• Cabinet Directive on getting projects built in Canada – The Government has issued a Cabinet Directive meant to run in parallel with the Bill to ensure that internal Federal decisions are rendered within the one-year timeframe.

Part 2: Keep Canada Moving

Part 2 proposes the integration of Canada’s transportation systems into national trade corridors. To achieve this, the Bill allows for the:

• Designation of “National Trade Corridors”
• Creation of a “National Trade Corridors Council”
• Implementation of a “Tell Us Once, Tell Us Digitally” approach to reduce regulatory red tape
• Extension of the interswitching pilot in the prairies for 48 months to provide shippers with increased options, but only after a reliable trading relationship with the United States is resumed
• Modernization of transportation security clearances to address insider threats and broader public safety risks
• Modernization of port governance

“By modernizing our transportation system and reducing red tape, we are helping move goods more quickly, strengthening supply chains, attracting investment and reinforcing Canada’s position as a reliable trading partner,” said Minister of Transport Steven MacKinnon. “These measures would help create jobs, support businesses and build a stronger economy for Canadians.”

Part 3: Canada Strong for All

Part 3 proposes amendments to Parts I and III of the Canada Labour Code and the Wage Earner Protection Program Act. The Government has outlined three key elements to Part 3 of the Bill.

1.     Strengthening collective bargaining

Measures within the Bill outline mandatory post-dispute remediation, earlier engagement, extended conciliation (from 60 to 90 days), geographic certification, expedited grievance arbitration and enhanced support for initial collective agreements.

2.     Reforms of Section 107

Currently, Section 107 allows a minister to refer parties in deadlock to the Canada Industrial Relations Board in order to end a work stoppage and move to binding arbitration.  Under the proposed changes, the reforms would include orders for resumption of operations, extension of collective agreement terms and the establishment of binding arbitration.

Critically, the authority to exercise section 107 would lie with the Minister, but only after fulfilling two conditions:

• The Minister must be of the opinion that a strike or lockout would have a “significant adverse national impact”
• The Minister must consider a report prepared by a “special mediator” appointed to the issue

The Bill clarifies that the “national interest” could relate to effects on the Canadian economy. It further provides that the Minister would consider whether a strike or lockout causes or might cause “serious social disruption” and whether exercising the section 107 powers would impact the right to freedom of association.

“This legislation,” said Minister of Jobs and Families Patty Hajdu, “will protect the right to strike while reinforcing the responsibility of unions and employers to negotiate in good faith.”

Relatedly, the Government has indicated it will hire 26 new staff at the Canada Industrial Relations Board to clear complaint backlogs.

3.     Worker protections

Part 3 addresses worker protections, including measures targeting worker misclassification and wage theft, workplace safety, contract retendering, sustaining the Wage Earner Protection Program and clarifying paid medical leave as a minimum floor. The Government has committed to adding 100 new health and safety officers, representing an approximately 70% increase in inspection capacity.

Key takeaways

Bill C-39, the Building Canada Strong Act, represents a sweeping effort by the Government of Canada to balance the need for accelerated Federal decision-making and the country’s commitments to environmental protection, Indigenous reconciliation and worker welfare. At its core, the Bill seeks to compress what has historically been a five-year approvals process into a one-year timeline through consolidated permitting, designated project assessors, a new Crown Consultation Hub and a parallel Cabinet Directive. The Bill’s creation of National Trade Corridors and modernization of port governance represents a push to better integrate Canada’s supply chains and reduce regulatory red tape. On the labour front, the Bill proposes changes to collective bargaining processes, introduces new conditions for ministerial intervention under section 107 and includes language acknowledging the right to freedom of association.

Underpinning the Bill is a significant investment in enforcement capacity, including 100 new health and safety officers and 26 new staff at the Canada Industrial Relations Board, aimed at tackling worker misclassification, wage theft and complaint backlogs. As the Bill moves through the legislative process, stakeholders will want to monitor how these ambitious timelines and structural reforms take shape in practice. The Bill may have consequences for various entities including energy and infrastructure proponents, transportation and shipping industries, environmental advocates, Federal employers, labour organizations and Indigenous communities.

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