The Primary Care Act, 2025 sets out the Government of Ontario’s formal objectives for the publicly funded primary care system and requires the Minister of Health to publish an annual report on progress. The Act lists six substantive objectives — from province-wide access and team-based care to digitally enabled patient access to personal health information — and directs the Minister to report, among other things, the percentage of insured persons with an ongoing relationship with a primary care clinician or team.
The statute is an aspirational statute: it frames expectations and creates reporting and regulatory authority but expressly disclaims the creation of private law rights or duties and does not attach funding or enforcement tools. For health system planners, clinicians, digital vendors and patient advocates the Act matters because it formalizes performance measurement and opens the door to regulation and KPIs — while leaving implementation details, timelines and resources to subsequent policy instruments and regulations.
At a Glance
What It Does
The Act declares six system-level objectives for publicly funded primary care and requires the Minister to prepare a publicly available annual report on progress, including the percentage of insured persons with an ongoing relationship to a primary care clinician or team. It gives the Lieutenant Governor in Council regulation-making powers to add reporting details (including key performance indicators) and to govern how reports are published.
Who It Affects
Directly affected parties include the Ministry of Health (reporting and policy-setting), primary care clinicians and teams who will be measured and described in provincial reporting, health system planners (including Ontario Health and regional delivery organizations), and insured persons — especially those without an existing primary care relationship. Digital health vendors and privacy officers are implicated by the Act’s emphasis on digitally-integrated access to personal health information.
Why It Matters
By codifying objectives and mandatory public reporting, the Act reframes primary care as a measurable, system-level priority and creates a statutory basis for future regulations and KPIs. However, because the Act explicitly avoids creating enforceable private rights and ties no funding to the objectives, its practical impact will depend on follow-up regulations, reporting design, and government implementation choices.
More articles like this one.
A weekly email with all the latest developments on this topic.
What This Bill Actually Does
The Primary Care Act, 2025 is short and targeted. Rather than redesigning funding or delivery models, it sets out what the provincial government wants the primary care system to achieve.
Section 3 lists six objectives that range from ensuring province-wide opportunities for an ongoing documented relationship with a clinician or team, to ensuring digitally integrated patient access to personal health information. The Act uses the language of opportunity and responsiveness rather than entitlement.
The central operational mechanism is reporting. The Minister must prepare a public annual report about how the government is working toward those objectives; the Act requires the report to include a basic metric — the percentage of insured persons with an ongoing primary care relationship — and allows the executive to add further indicators by regulation.
The statute sets a clear timeline for public reporting: the first report must be published within one year of the Act coming into force, and then annually.The Act deliberately limits legal consequences. It contains two provisions that constrain legal fallout: it states that the Act and its regulations do not create private law rights or duties (no private cause of action flows from its provisions), and it says that failure to comply with the Act or regulations does not invalidate existing policies or decisions.
Those clauses make the Act a statement of policy intent and a data and transparency tool rather than a vehicle for litigation or immediate operational change.Finally, the Act delegates significant detail to the Lieutenant Governor in Council. The government can regulate definitions, expand or clarify objectives, prescribe additional reporting content (including KPIs), and set how reports are made public.
That delegation concentrates substantive implementation choices in regulations and means the Act’s real effects will be determined by subsequent regulatory design and by how the government chooses to resource and enforce those priorities.
The Five Things You Need to Know
Section 3 sets six explicit objectives for the primary care system, including a province‑wide opportunity for a documented ongoing relationship, coordinated care, timely access, inclusivity, digitally integrated patient access to personal health information, and responsiveness with public performance information.
Section 4 requires the Minister to publish a public annual report; the first report must be made available within one year of the Act coming into force and subsequent reports annually thereafter.
Section 4(2)(1) mandates that the Minister’s report include the percentage of insured persons in Ontario who have an ongoing relationship with a primary care clinician or team, creating a baseline metric for attachment.
Section 7 gives the Lieutenant Governor in Council regulatory authority to prescribe additional reporting details (including key performance indicators) and to govern how the report is published, effectively allowing the executive to determine measurement and disclosure rules.
Sections 5 and 6 limit legal exposure: the Act expressly does not create private law rights or duties (no private cause of action) and states that non‑compliance with the Act or its regulations does not affect the validity of existing policies, directives, instruments or decisions.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Definitions and scope
This short definitions section adopts terms from existing statutes: ‘insured person’ follows the Health Insurance Act and ‘personal health information’ follows PHIPA. That choice ties the Act directly into Ontario’s existing health and privacy frameworks and signals that subsequent obligations about data and access will operate against PHIPA’s baseline protections.
Purpose — an explicit policy statement
The Act’s purpose clause frames it as a statement of government vision: to make clear what insured persons should expect when accessing primary care. This is not a technical provision with operational mechanics, but it serves as the statutory rationale that regulators and ministers will cite when crafting regulations and policies under the Act.
Six system objectives (province‑wide, connected, convenient, inclusive, empowered, responsive)
Section 3 is the core substantive text and lists six objectives for the publicly funded primary care system. The wording matters: the Act promises that insured persons should have the opportunity to obtain certain things (e.g., a documented ongoing relationship, digital access to personal health information) rather than guaranteeing outcomes. The inclusion of digital access and responsiveness signals a provincial priority toward interoperability, transparency and performance measurement.
Annual reporting requirement and required metric
Section 4 obliges the Minister to prepare an annual public report on progress toward the objectives and explicitly requires the report to include the percentage of insured persons with an ongoing relationship to a primary care clinician or team. The section sets hard timing — first report within one year of the Act coming into force and annually thereafter — which creates predictable reporting cadence but leaves the selection and methodology for additional indicators to regulation or ministerial choice.
No private legal rights; non‑retroactivity of non‑compliance
Section 5 disclaims the creation of private law causes of action or fiduciary duties, limiting litigation risk stemming from unmet objectives. Section 6 underlines that failure to follow the Act or regulations does not invalidate policies, directives, instruments or decisions. Together these provisions make the statute a policy and transparency tool that avoids creating enforceable private entitlements or disruptive legal remedies.
Delegated regulatory powers and scope for KPIs
Section 7 grants broad regulation‑making authority to the Lieutenant Governor in Council, including clarifying definitions, adding detail to objectives, prescribing report contents (explicitly allowing KPIs), and governing how reports are published. That delegation shifts many implementation choices from the statute to future regulations, so the Act’s practical reach depends heavily on the contents of those regulations and on the government’s choices about performance measurement and public disclosure.
Commencement and short title
The Act comes into force on Royal Assent and is cited as the Primary Care Act, 2025. Because the statute commences immediately, the one‑year window for the first report starts on Royal Assent, creating a binding schedule for the initial public disclosure.
This bill is one of many.
Codify tracks hundreds of bills on this topic across all five countries.
Explore this topic in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Insured persons currently without a primary care relationship — the Act prioritizes measuring and reporting attachment rates, which can drive policy to expand access and target unattached populations.
- Patient advocates and researchers — public annual reports and prescribed KPIs create new, accessible performance data for tracking equity, access and system responsiveness.
- Primary care teams that invest in digital integration — the Act’s 'empowered' objective explicitly values digitally integrated access to personal health information, which can favour teams able to demonstrate interoperability and digital patient access.
- Provincial health system planners and policymakers — the statutory objectives and mandated reporting give planners a policy framework and a statutory hook for designing coordinated, measurable reforms.
- French language and Indigenous communities — the statute explicitly includes commitments to respect the dignity and rights of diverse communities, creating a statutory basis for targeted reporting and program design.
Who Bears the Cost
- Ministry of Health — the Act creates an ongoing reporting obligation that requires staff time, data collection, analysis and publication resources; the statute contains no new funding, so costs will be borne within existing budgets unless new allocations are made.
- Primary care providers and clinics — reporting and any future KPIs or documentation requirements will increase administrative and data‑management burdens, particularly for small or rural practices with limited IT capacity.
- Health IT vendors and digital infrastructure programs — the emphasis on digitally integrated access creates demand for interoperability work, upgrades and possible compliance with provinceally mandated technical standards.
- Privacy officers and organizations handling PHI — increased reporting and patient access initiatives will raise operational privacy and consent questions under PHIPA, increasing compliance work and potential liability exposure if systems are not properly secured.
- Regional delivery organizations (e.g., Ontario Health partners) — coordinating services to meet ‘connected’ and ‘responsive’ objectives may require program redesign and added coordination costs at the regional level.
Key Issues
The Core Tension
The Act balances two legitimate aims that pull in opposite directions: it seeks to make primary care performance measurable and transparent while avoiding the creation of enforceable individual rights. That trade‑off protects the government from litigation and operational disruption but leaves patients and providers dependent on future regulations, funding decisions and administrative follow‑through to turn aspirational objectives into tangible improvements.
The Act is deliberately aspirational and short; its utility depends on the content of future regulations and on administrative choices. That means two implementation risks.
First, the use of the word “opportunity” throughout the objectives creates ambiguity: provinces can report progress without legally guaranteeing that individuals will obtain a primary care relationship. Second, the delegation to the Lieutenant Governor in Council to prescribe KPIs and public reporting formats concentrates technical decisions at the executive level, making transparency and comparability contingent on regulatory design rather than statutory standards.
There are also tensions around measurement and privacy. Mandating a headline metric (percentage with an ongoing relationship) is useful for accountability, but it invites methodological disputes (who counts as 'ongoing' or 'documented') and perverse incentives (box‑checking rather than meaningful continuity).
The Act’s push for digitally integrated patient access sits against PHIPA obligations; expanding access to personal health information will require careful privacy impact assessments and likely investments in secure, interoperable systems — none of which the statute funds or prescribes. Finally, the explicit denial of private legal rights limits judicial enforcement, which reduces litigation risk but also limits legal remedies for patients who experience gaps in access.
There's more to this law than the bill.
Codify Laws traces every connection across the legislative lifecycle.