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Plan to Protect Ontario Act (Budget Measures), 2025 — omnibus fiscal and regulatory package

A single Act repackages tax-rate changes, a new fertility tax credit, CIRO investigatory powers, limits on municipal tolling and bike-lane rules — all with concrete tax, enforcement and governance effects.

The Brief

Bill 24, enacted as the Plan to Protect Ontario Act (Budget Measures), 2025, is an omnibus statute that amends dozens of provincial laws to implement budget choices and regulatory changes. It touches tax rates (gasoline, liquor, fuel), creates a refundable Ontario fertility treatment tax credit, authorizes large-scale provincial borrowing, adjusts enforcement regimes (securities, commodity futures, tobacco) and changes municipal powers related to tolls and certain bicycle lanes.

The bill also adds operational controls over automated camera enforcement and tightens ministerial oversight of some Crown corporations.

For professionals: the Act is a patchwork of immediate compliance changes (new tax rates and notice rules), structural shifts (CIRO investigatory powers and immunity provisions in securities and commodity futures law), and governance limits (municipal toll bans; ministerial approval requirements for the Ontario Cannabis Retail Corporation). The measures carry both administrative deadlines and new numerical thresholds that will matter to finance, municipal, transportation and compliance teams across the province.

At a Glance

What It Does

The Act bundles targeted tax-rate updates and new tax credits, grants investigative and confidentiality powers to CIRO-appointed investigators under both the Securities Act and the Commodity Futures Act, restricts municipal and City of Toronto toll powers, mandates restoration or reconfiguration of certain Toronto bicycle lanes for motor-vehicle traffic, and places new rules around automated camera enforcement contracts and disclosure.

Who It Affects

Affected parties include provincial finance and revenue branches, public and private sector employers subject to assessment and employer-health notice rules, capital markets participants regulated by CIRO, Ontario municipalities (notably Toronto), brewers and distillers, fuel purchasers (including propane users and interjurisdictional carriers), and individuals claiming fertility treatment expenses.

Why It Matters

The Act consolidates fiscal policy choices (tax cuts, tax reclassifications and a refundable credit) with regulatory and enforcement upgrades that increase penalties and give CIRO-like staff investigation powers and legal protections — a meaningful shift in how provincial regulators and the province itself will exercise oversight and raise or forego revenue.

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What This Bill Actually Does

The Act is a classic budget omnibus: dozens of discrete amendments collected into schedules that together change tax settings, provincial borrowing authority, enforcement tools and municipal powers. Several tax statutes are recalibrated — for example, the Gasoline Tax and Fuel Tax are reworked so propane is treated differently and gasoline tax rates are reset; the Liquor Tax adjustments introduce lower rates for microbrewers and change how certain beer is classified; and the Tobacco Tax increases fines and creates new threshold offences tied to quantities.

The Taxation Act adds a refundable Ontario fertility treatment tax credit that covers 25% of eligible expenses up to a $20,000 cap per year and creates repayment rules tied to a manufacturing investment credit.

On regulatory enforcement, the Act adds parallel investigative regimes to both the Securities Act and the Commodity Futures Act that let the Canadian Investment Regulatory Organization’s CEO appoint CIRO employees as investigators with broad summons and production powers. The new provisions build in confidentiality controls, limited disclosure pathways (including Tribunal authorization and Commission disclosure rules), and a statutory immunity for current and former CIRO directors, officers and staff acting in good faith — while preserving Crown-initiated proceedings.

Separately, monetary penalties under securities and commodity futures statutes, and administrative penalties by the Capital Markets Tribunal, are raised substantially.Municipal authority is constrained in two ways. First, the Act removes municipal power to designate toll highways (including a targeted change to the City of Toronto Act and the Municipal Act).

Second, it amends the Highway Traffic Act to require the provincial Minister to restore certain lanes on named Toronto streets to motor-vehicle use (by reconfiguring or removing bicycle lanes) and gives the Lieutenant Governor in Council the power to order similar restorations. The Highway Traffic Act additions also set rules for automated camera enforcement: municipalities must publish camera locations, may be directed by the Minister to change system operations, and municipal contracts cannot tie vendor payments to the number or revenue of offences.Other practical changes: the Employer Health Tax and Assessment Acts expand permitted electronic delivery of notices and set standard delivery rules; the Financial Administration Act allows the Minister of Finance to deal in bond forward agreements; the Ontario Loan Act authorizes up to $27 billion in Crown borrowing subject to expiry limits; the Ontario Cannabis Retail Corporation must obtain ministerial approval for all bylaws and may receive ministerial directions on net profit remittances; and the Historical Parks Act creates a dedicated account for park revenues and expenses.

Each Schedule contains commencement rules — some provisions take effect on Royal Assent, others on named dates such as July 1, 2025, or days to be named by order in council.

The Five Things You Need to Know

1

The Ontario fertility treatment tax credit is refundable and equals 25% of the lesser of $20,000 and an individual’s eligible fertility treatment expenses for a taxation year ending after Dec. 31, 2024.

2

Gasoline tax rates are set at 9 cents per litre (gasoline) and 17.7 cents per litre (leaded gasoline); propane is removed from the Gasoline Tax Act (effective July 1, 2025) and treated separately in the Fuel Tax Act.

3

The Securities Act and the Commodity Futures Act let CIRO’s CEO appoint CIRO employees as investigators with Superior Court–level summons and production powers, confidentiality orders, restricted disclosure pathways, and statutory protection from personal liability for good-faith conduct.

4

The Act bans municipalities (including the City of Toronto) from designating, operating or maintaining toll highways and requires the Minister to restore or reconfigure bicycle lanes for motor-vehicle use on specified Toronto streets (Bloor, University, Avenue Road, Yonge).

5

Tobacco offences and fines are substantially increased, including new quantity-based offences (e.g.

6

possession thresholds of 10,000+ cigars or 100,000+ grams triggering much higher minimum and maximum fines and potential imprisonment).

Section-by-Section Breakdown

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Schedule 1 (Assessment Act)

Standardizes notice delivery and expands electronic delivery, plus disclosure regulation power

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This Schedule rewrites delivery language across the Assessment Act to require notices be "provided" in writing and allows electronic delivery where the recipient consents or has given an address for delivery. It replaces various references to mailed or printed notices, sets time frames for notice of adjustments and reconsiderations, and gives the Minister regulation power over certain disclosures by entities that receive assessment data. Practically, assessment offices and tax administrators must update delivery-processes, consent capture for email delivery, and record-keeping to meet the new statutory language and the 90–180 day timing rules for notices.

Schedule 3 & 17 (Commodity Futures Act; Securities Act)

Authorizes CIRO-appointed investigators, confidentiality orders, and personal immunity provisions

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Both Acts gain near-identical new parts empowering the CIRO CEO to appoint CIRO employees as investigators with powers to summon witnesses and compel document production with the same enforcement weight as the Superior Court. The regimes allow the CEO to issue investigation orders, limit disclosure (confidentiality orders), and permit Tribunal oversight of revocations or variations. They also insulate current and former CIRO personnel from civil liability for good-faith acts while preserving Crown prosecutions. That combination expands administrative investigatory capacity but also creates tightly circumscribed confidentiality and review pathways that will shape how market misconduct probes are conducted and challenged.

Schedule 2 & 13 (City of Toronto Act, 2006; Municipal Act, 2001)

Removes municipal tolling power

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The Acts are amended to say municipalities — including Toronto — do not have the power to designate, operate or maintain toll highways, regardless of the municipality’s purpose for tolling. The removal of the related regulation-making power for Toronto follows from the same Schedule. Municipalities that had planned toll-financed projects will lose that financing option and must pivot to alternative funding models; legal and procurement teams should review any pre-existing toll contracts and financing plans for termination or amendment risk.

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Schedule 6 & 7 (Fuel Tax Act; Gasoline Tax Act)

Reclassifies propane, sets gasoline tax rates and tightens refund claims

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The Gasoline Tax Act removes propane from taxable gasoline and the Fuel Tax Act’s definition of fuel is updated to include propane under a reworked framework. The Act sets explicit gasoline tax rates (9¢/L gasoline; 17.7¢/L leaded gasoline) and creates transitional and refund claim limits tied to the removal of propane from gasoline taxation (notably a July 1, 2025 effective date and a July 1, 2027 deadline to claim overpayments related to propane). Fuel suppliers, fleet operators and interjurisdictional carriers need to adjust billing, inventory valuation and refund claim processes accordingly.

Schedule 9 (Highway Traffic Act)

Directed lane restorations and automated camera enforcement rules

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This Schedule requires the Minister to restore motor vehicle lanes on specified Toronto streets by reconfiguring or removing bicycle lanes, and empowers the Lieutenant Governor in Council to order similar actions elsewhere. It creates Part XIV.5 governing automated camera enforcement: municipalities operating cameras must publish camera locations, may be required to display signs, must provide data to the Minister on request and may be directed to change operations; contracts cannot compensate vendors based on number of offences or revenue. Municipal procurement and traffic-engineering teams will face both operational directives and constraints on contract structures.

Schedule 11 & 18 (Liquor Tax Act; Taxation Act)

Microbrewer and distillery tax changes plus new fertility credit

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The Liquor Tax Act lowers certain basic tax rates for microbrewers and halves the basic tax rate that applies to purchases from distillery retail stores (from 61.5% to 30.75% for specified provisions). The Taxation Act creates a refundable Ontario fertility treatment tax credit equal to 25% of eligible fertility treatment expenses up to $20,000 for tax years ending after Dec. 31, 2024, and adds the credit to several existing tax-credit frameworks with a mandatory five-year review. Accounting and payroll teams should model the cash-flow and eligibility implications; tax compliance needs updated claim and review procedures.

Schedule 16 & 19 (Ontario Loan Act, 2025; Tobacco Tax Act)

Authorized Crown borrowing and tougher tobacco enforcement

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The Ontario Loan Act authorizes the Crown to borrow up to $27 billion (in addition to other borrowing authority) with a statutory sunset on orders inviting borrowing after Dec. 31, 2027 and constraints on borrowing agreements beyond Dec. 31, 2028. The Tobacco Tax Act raises base fines, adds higher maximums and creates quantity-linked offences with much steeper penalties and possible imprisonment for large-scale possession or trafficking. Public finance teams gain an explicit borrowing instrument while enforcement agencies gain stronger tools and penalties for tobacco-related offences.

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

  • Individuals incurring eligible fertility treatment expenses — they receive a refundable tax credit equal to 25% of eligible expenses up to a $20,000 cap per taxation year, improving affordability and cash-flow for those pursuing treatments not otherwise covered.
  • Microbrewers, certain small beer manufacturers and distillery retail customers — the Liquor Tax Act revisions and Small Beer Manufacturers’ tax credit changes reduce effective tax burdens on qualifying producers and purchases, potentially improving margins or retail pricing flexibility.
  • CIRO and provincial regulators — new investigator appointment powers, stronger confidentiality tools and higher administrative-penalty caps enlarge regulators’ investigatory and enforcement toolkits, enabling faster, on-staff inquiries without relying solely on external processes.

Who Bears the Cost

  • Municipal governments — they lose the option to toll highways as a funding mechanism and face constraints on automated-camera vendor contract structures, potentially increasing direct operating costs or reducing revenue options for road projects.
  • Fuel purchasers and provincial revenue planners — removing propane from gasoline taxation and lowering certain fuel rates reduces provincial fuel tax revenue and forces fuel distributors and carriers to change invoicing, inventory accounting and refund claims processes (including a July 1, 2027 window for certain overpayment claims).
  • Market participants (brokerages, registrants and firms regulated by CIRO) — the appointment of CIRO employees as investigators with Superior Court–style powers increases compliance and legal costs, elevates litigation risk around Tribunal review and confidentiality orders, and shifts the operational burden toward more formalized inquiries.

Key Issues

The Core Tension

The central dilemma is provincial consolidation of fiscal control and enforcement capability versus local autonomy and procedural transparency: the province reduces municipal financing options and centrally directs road and enforcement operations while simultaneously expanding powerful, partially non-public investigatory tools (with liability shields) for market enforcement — a trade-off between efficiency, fiscal control and enforcement clout on one hand and local decision-making, transparency and accountability on the other.

The Act stitches together fiscal giveaways (select tax reductions and a refundable fertility credit) with expanded administrative enforcement power and tightened municipal constraints. That combination creates implementation frictions: shifting tax classifications for fuels and alcohol requires coordinated changes across collection, accounting and refund systems and leaves open fiscal trade-offs if consumption patterns change (for example, shifting from gasoline to propane).

The CIRO investigator provisions improve investigatory agility but—paired with confidentiality orders and personal-immunity clauses—raise questions about transparency, independent review and potential chilling effects on whistleblowing; the Tribunal and Commission pathways are the only built-in checks, and their functioning will determine how balanced oversight is in practice.

On municipal matters, the removal of tolling power and the Minister-directed reconfiguration of bicycle lanes create a direct tension between provincial uniformity and local autonomy. Municipalities that expected toll revenue for capital projects must identify replacement funding quickly, and traffic-planning decisions that affect local modal priorities (cycling versus vehicle flow) are centralized.

The automated camera contract restriction (no revenue- or offence-linked vendor pay) curbs perverse incentives but shifts financial risk back to municipalities or the provincial purse, and the Act leaves regulatory details to the Lieutenant Governor in Council and regulations — meaning operational clarity will lag statutory change and require active regulatory drafting and early guidance.

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