Bill 54 amends the Government Advertising Act, 2004 to reverse several amendments made in 2015 and return the Act to its earlier form. The bill removes the statute’s “preliminary” review language, restores the Auditor General’s role in issuing an opinion on whether an advertisement, printed material or message meets statutory standards, and expressly prohibits government offices from publishing, distributing or broadcasting material before the head of the office has received (or been deemed to have received) the Auditor General’s notice.
It also reinstates explicit standards—such as a ban on using the name, voice or image of ministers or MPPs and a prohibition on primarily partisan objectives—and tightens restrictions during election periods with limited exceptions.
This is a compliance-first bill: it converts editorial judgments about government messaging into a formal review process with operational consequences for communications teams, procurement and program delivery. Communications directors, vendors, legal counsel and the Office of the Auditor General will need to adjust workflows and timelines; political actors and watchdogs will be watching how “partisan” and “time sensitive” are interpreted in practice.
At a Glance
What It Does
The bill requires that any government advertisement, printed material or conveyed message be submitted to the Office of the Auditor General for review and forbids publishing or distributing it until the head of the government office receives notice of the review results. If the Auditor General finds the item fails the statutory standards, its use is forbidden; revised versions must be re‑reviewed. It reinstates specific content standards and creates election-period blackout rules with narrow exceptions.
Who It Affects
Directly affects provincial government offices (communications and program heads), the Office of the Auditor General, external advertising vendors and media/printing suppliers, and political parties and opposition MPPs who challenge partisan uses of public funds. It also touches legal and procurement teams that manage contracts and delivery schedules.
Why It Matters
The bill moves compliance upstream: heads of government offices carry final responsibility for withholding items pending audit opinion, and the Auditor General regains explicit gatekeeping power. That changes campaign‑period exposure for the governing party, imposes new timing constraints on public information campaigns, and raises resourcing questions for the OAG and for offices that must synchronize delivery with prescribed review timelines.
More articles like this one.
A weekly email with all the latest developments on this topic.
What This Bill Actually Does
Bill 54 systematically rolls back post‑2015 changes and restores a pre‑2015 regime in which the Auditor General performs substantive reviews of government communications. The statute redefines the covered items as “reviewable” advertisements, printed matter or messages and eliminates the language that previously allowed for only “preliminary” reviews.
Under the reinserted framework, an item must be submitted to the OAG and the head of the office may not use it until they receive the OAG’s notice of the review outcome or are deemed to have received that notice.
The bill sets out a concrete list of standards an item must meet: it must serve specific public purposes (informing about government policies or rights, encouraging public‑interest behaviour, or promoting Ontario economically), must disclose that it is paid for by the Government of Ontario, must not include the name, voice or image of cabinet ministers or MPPs (with a geographic exception for out‑of‑province targets), and must not be partisan or principally intended to foster a positive impression of the governing party. The Auditor General is explicitly authorized to determine whether an item’s primary objective is partisan, using prescribed and discretionary factors.Procedurally, the bill creates a two‑stage practical workflow: submission, then review, then either notice of compliance or notice of non‑compliance.
If the OAG indicates non‑compliance, the office cannot use the item and must resubmit proposed revisions for a fresh review. The statute preserves a “deemed notice” safety valve: if the OAG does not notify the head within the prescribed number of days, the head is deemed to have received notice that the item meets the standards, which functions as an automatic clearance in the event of OAG delay.Finally, the bill reinstates strict restrictions during election periods.
Items that have received notice or deemed notice are still banned from publication, distribution or broadcast during defined pre‑election windows unless they meet narrow exceptions for revenue generation, time sensitivity, or other prescribed criteria. The combination of pre‑use prohibitions, strict standards on content, the reintroduced role for the Auditor General and the election blackout creates a compliance regime that will force communications planning to account for audit timelines and increase the legal and operational oversight of taxpayer‑funded messaging.
The Five Things You Need to Know
The bill removes the word “preliminary” from review provisions and prohibits any publication, distribution or broadcast of an item until the head of the government office receives (or is deemed to have received) the Auditor General’s notice of the review.
If the Auditor General notifies a head that an item does not meet the Act’s standards, the government office is expressly forbidden from using that item; any revised version must be resubmitted for a further review before use.
The statute lists required standards: items must pursue enumerated public purposes, include a ‘paid for by the Government of Ontario’ statement, not use the name/voice/image of Executive Council members or MPPs (with an exception for items primarily targeted outside Ontario), and must not be partisan or primarily intended to bolster the governing party.
The bill adds an election‑period prohibition that bars use of items during writ periods (and an additional 60‑day pre‑writ window for certain elections), subject only to narrow exceptions for revenue‑generating items, time‑sensitive items, or other prescribed criteria.
The Office of the Auditor General must notify heads within prescribed days; if it fails to do so the head is deemed to have received notice that the item (or revised item) meets the standards—creating automatic approval when the OAG misses its deadline.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Definitions adjusted and 'standards' definition removed
The bill replaces the definition of “item” with language covering reviewable advertisements, printed matter and messages and repeals the distinct statutory definition of “standards.” Removing the standalone “standards” definition pushes the test for acceptable content into the substantive section that lists required standards; it narrows textual ambiguity but also concentrates interpretive importance in the standards section and in regulations the Lieutenant Governor in Council may prescribe.
Pre‑use prohibitions for ads, printed matter and messages
These sections add an operational rule across three media types: the head of a government office may not publish, distribute or convey an item until the head has received or is deemed to have received the Auditor General’s notice. They also make it unlawful to use an item if the OAG notifies the head that it fails the Act’s standards. Practically, these provisions convert the OAG opinion into a precondition for communication and shift the procedural burden onto heads of offices to withhold materials if the OAG raises concerns.
Substantive content standards and how to decide 'partisan'
Section 6 enumerates the test items must meet—reasonable means to specified public purposes, a funding disclosure, bans on minister/MPP imagery or voice, and an explicit prohibition on partisan purpose or primary objective to bolster the governing party. The Auditor General gets authority to deem an item partisan based on prescribed factors and any additional factors the Auditor General considers appropriate, which gives the OAG both a rulebook and discretionary space in borderline cases.
Review process, notices and revised submissions
These sections set the mechanics: the OAG must notify the head within prescribed days; failure to meet the timeline results in a deemed notice that the item complies. If the OAG finds non‑compliance, the office may prepare a revised version but must submit that revision for a new review and refrain from use until it receives notice. The deemed‑notice rule is consequential: it provides a backstop to prevent indefinite holdups but also creates timing incentives for government and auditors.
Election‑period blackout with narrow exceptions
This new subsection bars publication, distribution or broadcast of items during the writ‑to‑poll period for general elections and an additional 60‑day pre‑writ window for certain early elections, even where an item has been approved or deemed approved. Exceptions are limited to revenue‑generating items, time‑sensitive items, or items that meet other prescribed criteria. The section also requires offices to cease ongoing campaigns that began before the blackout unless the head judges cessation impracticable.
Regulatory powers and repeals
The bill removes several clauses that existed after 2015 and replaces others to reallocate regulatory authority: the Lieutenant Governor in Council will prescribe additional factors for the partisan test, timelines for notices, and criteria for election‑period exceptions. The repeal of certain subsections narrows what the regulations may have previously authorized and centralizes the remaining rulemaking into specific categorical prescriptions.
Commencement and short title
The Act will come into force on a day named by order of the Lieutenant Governor in Council and uses the short title End the Public Funding of Partisan Government Advertising Act, 2025. The delayed proclamation clause gives government flexibility to align implementation with administrative readiness—important in light of anticipated resourcing and policy adjustments for affected offices and the OAG.
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
- Auditor General’s Office — Regains clearer statutory authority to adjudicate government messaging and to bar use of non‑compliant items, strengthening its oversight role over public communications.
- Opposition MPPs and political watchdogs — Benefit from tighter constraints on taxpayer‑funded messaging that could otherwise be used for partisan advantage, increasing transparency and a clearer enforcement pathway.
- Taxpayers and the general public — Gain stronger guardrails against overtly partisan government advertising paid for from public funds, which may reduce the risk of election‑period message laundering through government channels.
- Government heads who want clarity — Communications and program heads who prefer codified rules over ad hoc judgments receive explicit standards and a predictable, statute‑based process to follow.
Who Bears the Cost
- Provincial government communication offices and heads — Face new operational burdens to submit items, withhold publishing until clearance, and potentially alter campaign schedules; responsibility for compliance sits with the head of office.
- Office of the Auditor General — Will likely need additional resources and faster turnaround capacity to avoid triggering deemed approvals or bottlenecks, increasing OAG workload and possibly requiring budgetary adjustments.
- Advertising vendors and media/print suppliers — Encounter timing uncertainty, cancellation risk and potential last‑minute changes if items are held or returned for revision, complicating procurement and delivery.
- Governing party and associated program teams — May lose a communication channel they previously used for politically favorable messaging and must navigate election blackout periods that constrain messaging timing.
Key Issues
The Core Tension
The core tension is between preventing the partisan use of public funds for political advantage and preserving the government’s ability to communicate timely, necessary information to the public: enforceable, pre‑use audit controls reduce partisan risk but risk delaying or chilling legitimate public communications—especially during emergencies or time‑sensitive operations—unless accompanied by clear, resourced procedures for rapid review.
The bill tightens oversight but creates several implementation tensions. Most notably, the deemed‑notice mechanism protects government offices from indefinite delay by the Auditor General, but it also produces a timing game: if the OAG misses its statutory window, items become automatically approved, which could undermine the bill’s preventive intent.
Conversely, if the OAG becomes more conservative in borderline cases to avoid being reversed later, offices may face more frequent non‑use directives and operational paralysis.
The election‑period exceptions are a second area of uncertainty. The statute preserves narrow exceptions for “time sensitive” or revenue‑generating items and delegates the rest to prescribed criteria; that delegation is sensible administratively but invites contested interpretations and potential litigation over what counts as time sensitivity or revenue generation.
Finally, the bill expands the OAG’s discretionary role in deciding whether an item’s primary objective is partisan. That discretion aids flexible enforcement but raises questions about predictable standards and appeals or review mechanisms for disputed decisions.
There's more to this law than the bill.
Codify Laws traces every connection across the legislative lifecycle.