The Protect Our Food Act, 2025 establishes a Foodbelt Protection Plan Advisory Committee to develop recommendations for creating and protecting a geographically continuous agricultural land base (the “Foodbelt”). The Committee must be appointed quickly, consult broadly, and deliver a public report with specific recommendations within 12 months of Royal Assent.
The Bill also amends the Planning Act to create a procedural barrier to converting certain farmland: municipal councils and the Minister may not change zoning or permitted uses for land zoned for “prescribed agricultural uses” as of commencement unless an Agricultural Impact Assessment (AIA) has been carried out in accordance with regulations. The Act gives the Lieutenant Governor in Council rule-making power to define the prescribed uses and to govern AIA content and process — which will determine the law’s practical scope and bite.
At a Glance
What It Does
Creates an expert advisory committee charged with recommending the boundaries and protections for a continuous Foodbelt and requires an AIA before any rezoning of land zoned for prescribed agricultural uses at the time the Act comes into force. The AIA requirement applies to both municipal zoning by-laws and Minister’s Zoning Orders (MZOs).
Who It Affects
Ontario farmers and agricultural organizations, municipal planning councils, provincial planners and the Minister of Agriculture, Food and Agribusiness, developers and aggregate operators who target agricultural lands that may be designated as part of the Foodbelt.
Why It Matters
The bill uses a two-step approach — first design (committee report) then regulation-backed procedure (AIA requirement) — to try to preserve contiguous agricultural lands. Its effectiveness will hinge on how the government defines ‘prescribed agricultural uses’ and what it requires in an AIA.
More articles like this one.
A weekly email with all the latest developments on this topic.
What This Bill Actually Does
The Act sets up a named Foodbelt Protection Plan Advisory Committee made up of farmers, agricultural experts, soil scientists, professional planners and food/agricultural organizations. The government must appoint members within 60 days of Royal Assent and the Committee must publish recommendations within 12 months.
The Committee’s brief is broad: it must identify what farmland belongs in the Foodbelt, propose protections from conversion, recommend sensible exceptions (for example local food sales, agritourism and on‑farm processing), suggest tools to limit speculation (like land trusts or succession planning) and address soil health, aggregate extraction and any other protections it sees fit.
On the land‑use side, the Act inserts a new Planning Act provision that applies to land that was zoned for “prescribed agricultural uses” on the day the Act comes into force. For that land, municipal councils and the Minister are barred from changing the zoning or permitted uses unless an Agricultural Impact Assessment has been carried out in accordance with regulations.
The bill does not itself define the prescribed uses or the contents, qualifications or standards for an AIA — it delegates that detail to regulations under the Planning Act.The Act also requires procedural follow-up: once the Committee delivers its report, the Minister of Agriculture, Food and Agribusiness must report to the Legislature within 60 days about implementation progress (or table the report at the next session if the Assembly is not sitting). The practical effect is a mixed package of design-stage policy (the Committee’s recommendations) and a stoppage mechanism (AIA requirement) that can slow or condition rezoning of certain agricultural lands, subject to how regulations are drafted and enforced.
The Five Things You Need to Know
The Lieutenant Governor in Council must appoint Committee members within 60 days of Royal Assent and the Committee must publish its recommendations within 12 months.
Municipal councils cannot pass a zoning by-law that changes uses or zoning of land zoned for prescribed agricultural uses unless an Agricultural Impact Assessment (AIA) has been carried out under the regulations.
The Minister cannot issue a Minister’s Zoning Order (MZO) changing uses or zoning of that land unless an AIA has been carried out under the regulations.
Regulations under subsection 70(1) will (a) prescribe which agricultural uses trigger the AIA protection and (b) set rules governing the design, scope and conduct of Agricultural Impact Assessments.
The Committee’s mandate explicitly includes recommendations on identifying the Foodbelt, exceptions (e.g.
agritourism, local food sales, on‑farm processing), measures to reduce land speculation, soil health goals and limits on aggregate extraction.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Creates the Foodbelt Protection Plan Advisory Committee and sets appointment deadline
The Act establishes the Committee by name in both official languages and requires the Lieutenant Governor in Council to appoint members from five defined groups (farmers; agricultural experts; soil scientists; professional planners; food and agricultural organizations) within 60 days of Royal Assent. That appointment deadline compresses the design phase and signals that the government expects a quick, expert-led process rather than an open-ended inquiry.
Committee functions, consultation requirement and reporting timeframe
The Committee must produce recommendations for a Foodbelt Protection Plan addressing identification of contiguous farmland, protections against conversion, exceptions, anti‑speculation measures, soil health goals, and restrictions on aggregate extraction. It must consult broadly with the agricultural community and publish its report within 12 months. These provisions prescribe the scope of analysis but leave content choices — including precise boundaries and regulatory mechanisms — to the Committee and ultimately to the government.
Ministerial follow-up reporting to the Legislature
After the Committee’s report is delivered, the Minister of Agriculture, Food and Agribusiness must report to the Legislative Assembly within 60 days on implementation progress, or table the report at the next session if the Assembly is not sitting. This creates a required, time‑bounded accountability step but does not mandate any particular implementation outcome or timeline for adopting the Committee’s recommendations.
Agricultural Impact Assessment requirement before rezoning
The Act inserts a targeted provision into the Planning Act that applies only to land that was zoned for ‘‘prescribed agricultural uses’’ at the time the Protect Our Food Act comes into force. For that land, municipal councils and the Minister must not change zoning or permitted uses unless an Agricultural Impact Assessment has been carried out in accordance with regulations. The provision is procedural: it requires an assessment before rezoning but does not itself set criteria for approvals or prohibit ultimate rezoning if the AIA supports it.
Regulation‑making powers to define scope and AIA requirements
The amendment adds explicit regulation-making authority to prescribe what counts as agricultural uses that receive protection and to govern Agricultural Impact Assessments. In practice, the cabinet will determine which zoned lands are covered and the technical standards for AIAs — the regulatory choices will determine the Act’s territorial reach, technical burdens and enforceability.
Commencement and short title
The Act comes into force on Royal Assent and is cited as the Protect Our Food Act, 2025. Because the substantive protections are triggered by the status of zoning on the commencement day, the timing of Royal Assent and any pre-existing zoning maps will lock in which parcels are covered unless regulations broaden or narrow the definition of ‘prescribed agricultural uses.’
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
- Farmers with parcels inside any future Foodbelt — the Committee’s mandate and AIA requirement make conversion harder and create political and procedural barriers to losing productive farmland.
- Local food processors and on‑farm businesses — by singling out exceptions such as on‑farm processing and local sales, the bill explicitly preserves room for value‑added agriculture within the Foodbelt.
- Soil scientists and conservation organizations — the Committee’s explicit focus on soil health and aggregate extraction invites science‑based protections and creates a formal vehicle for technical recommendations.
- Land trusts and succession planners — the Committee is directed to consider anti‑speculation measures and succession planning, potentially increasing demand for these conservation tools and funding opportunities.
Who Bears the Cost
- Municipal planning departments — councils must ensure an AIA is completed before rezoning covered lands, creating administrative workload, costs for technical studies and potential delays to planning decisions.
- Developers and landowners seeking conversions — rezoning proposals will face additional procedural requirements (and uncertainty), which can increase project costs and timelines.
- The provincial government/Minister’s office — the government must appoint the Committee quickly, manage its process, receive and respond to the report and draft enabling regulations; if underfunded, implementation could be delayed.
- Aggregate extraction operators — the Committee is tasked to recommend restrictions on extraction in the Foodbelt, which could lead to reduced permitted areas or stricter conditions for pits and quarries.
Key Issues
The Core Tension
The central tension is between protecting contiguous productive farmland — which argues for strict, hard barriers to conversion — and preserving local flexibility for growth, infrastructure and farm businesses — which argues for exceptions and measured, case‑by‑case decisions; the bill tries to thread that needle by imposing an AIA gate and commissioning recommendations, but it leaves open whether that gate will be substantive protection or a procedural hurdle depending on regulatory design and political choices.
Two features will determine whether this law changes outcomes or merely adds process. First, the Act delegates critical definitions and technical standards to regulation: which agricultural uses are ‘‘prescribed’’ and what an AIA must contain are not in the statute.
That means the cabinet’s choices will largely define geographic scope and the substantive burden an AIA imposes. Second, the statute requires an AIA but does not say what findings in an AIA will permit or block rezoning.
An AIA could be advisory, or regulations could equip it with mandatory criteria — the bill leaves both pathways open.
Operationally, municipalities and applicants will face immediate practical questions: who pays for AIAs, what timelines apply, what professional qualifications will be required, and how AIAs interact with other provincial instruments (growth plans, Greenbelt protections, Provincial Policy Statement) and municipal official plans. The Committee’s recommended exceptions (e.g., agritourism, on‑farm processing) can also erode protections if drafted broadly; conversely, narrow exceptions could create hardship for viable farm businesses.
Finally, the Act contemplates reporting and advisory mechanisms but does not provide funding or enforcement mechanisms, raising implementation and capacity questions for both provincial and municipal actors.
There's more to this law than the bill.
Codify Laws traces every connection across the legislative lifecycle.