Bill 97 bundles dozens of budget and regulatory changes into one Act. Key elements include the amalgamation of 35 conservation authorities into eight regional authorities, major amendments to access-to-information and municipal FOI regimes, creation of a Protect Ontario Account Investment Fund to make provincially-directed investments, and a stand‑alone Ontario Loan Act authorizing up to $35 billion in borrowings.
The bill also touches taxes, liquor levies, pension rules, ticket resale limits and governance appointments across several public bodies.
The package reallocates powers and timelines: the province gains new regulatory and ministerial directions over conservation authorities’ transition, the FOI regimes move many timelines to “business days” and carve out records in ministerial custody, and the financial changes both expand the government’s investment authority and repeal certain prior requirements governing contingent liabilities. Taken together, these measures increase provincial control over environment governance, information access and fiscal tools — changes that affect municipalities, regulated entities and the public purse in material ways.
At a Glance
What It Does
Implements multiple budget measures across 17 schedules: it mandates the amalgamation and transition process for conservation authorities, establishes the Protect Ontario Account Investment Fund as a designated account for provincially-directed investments, modifies FOI laws to allow staged disclosure and extend response timeframes measured in business days, and enacts an Ontario Loan Act that authorizes borrowings up to $35 billion with specific expiry conditions.
Who It Affects
Participating municipalities and staff of conservation authorities, operators and users of secondary ticketing platforms, heads of provincial and municipal institutions subject to FOI, pension plan administrators and members (via new variable life benefits rules), and the Minister of Finance and agencies that will manage investments and borrowing.
Why It Matters
The bill shifts governance and operational control to provincial authorities and to provincial officials during transitions, alters the public’s practical access to government records, expands the Crown’s fiscal tools for investment and borrowing, and rewrites obligations for several regulated sectors — creating compliance, accountability and financial-risk consequences that stakeholders must analyze now.
More articles like this one.
A weekly email with all the latest developments on this topic.
What This Bill Actually Does
The Act is an omnibus budget implementation statute that reorganizes public programs and changes financial and administrative rules across multiple policy areas. The Conservation Authorities Act is rewritten to consolidate 35 existing conservation authorities into eight regional bodies (and to continue the Lakehead authority under a new name).
The province creates transition committees led by provincially-appointed project executives, sets detailed legal continuity rules for assets, liabilities and employment, and gives the provincial agency and Minister power to issue directions during the transition period. The transition date is defined (February 1, 2027, unless regulations change it), and a two‑year term for the first chief administrative officer is established, who will be the project executive by statute.
On information access, both provincial and municipal FOI Acts are changed to (1) require certain time limits to be calculated in business days, (2) allow institutions to propose staged delivery plans for large or complex requests, and (3) permit an additional extension of time in certain circumstances. The Acts also add explicit rules for privacy impact assessments, new breach reporting and notification duties for institutions, and carve-outs that exclude records in the custody or control of a minister (and certain records under the Enhancing Digital Security and Trust Act, 2024) from FOI — a change with retroactive effect for some records dating back to 1988.On fiscal and governance matters the Financial Administration Act is amended to create the Protect Ontario Account Investment Fund — a designated purpose account inside the Consolidated Revenue Fund for the Minister to make investments aimed at innovation, infrastructure and strategic priorities; proceeds are to be added back to the fund unless the Minister directs otherwise.
Separately, the Ontario Loan Act authorizes up to $35 billion in Crown borrowings for specified purposes, with limits on when orders in council may be made and when borrowings must be contracted. The Corporations Tax, Liquor Tax and Taxation Acts receive targeted tax and credit adjustments.
The Ticket Sales Act is tightened to cap secondary-market prices at the original total price plus platform fees, requires proof of original purchase price to platforms, and imposes recordkeeping and disclosure duties on platform operators. The Pension Benefits Act gains a new variable life benefit framework that allows a portion of pension benefits to be paid from funds whose payouts may vary with investment returns and mortality experience, and it adds specialized wind‑up and death‑benefit rules for those benefits.Scattered through the schedules are clauses that limit remedies and compensation in certain contexts (for example, extinguishing certain causes of action tied to the Bremner Boulevard/Skydome bus-parking regime and adding non-entitlement-to-compensation language in the Ticket Sales amendments), regulatory revocations, and changes to appointments and advisory processes for boards such as the Workplace Safety and Insurance Board.
Many of the changes come into force either on Royal Assent, on specified future dates, or on days to be named by order of the Lieutenant Governor in Council, leaving substantial implementation detail to regulations.
The Five Things You Need to Know
The bill consolidates 35 conservation authorities into eight regional conservation authorities (with the Lakehead Region continued as Northwestern Ontario Regional Conservation Authority) and establishes statutory transition committees to implement amalgamations.
It creates the Protect Ontario Account Investment Fund as a designated-purpose account within the Consolidated Revenue Fund and authorizes the Minister of Finance to make investments and retain proceeds, subject to ministerial direction.
The Ontario Loan Act authorizes Crown borrowing up to an aggregate $35 billion and limits the period during which orders authorizing borrowing may be made (no orders after Dec. 31, 2028) and when borrowings must be contracted (restrictions through Dec. 31, 2029 unless an agreement is entered).
FOI timelines and procedures change: response periods become measured in business days (e.g.
45 business days for initial responses), institutions may propose staged access plans, and certain records in the custody or control of ministers are removed from FOI coverage (with retroactive rules to Jan. 1, 1988).
The Ticket Sales Act now bans secondary-market prices that exceed the total price paid to the primary seller (plus platform fees/taxes), requires sellers to provide proof of original purchase price to platforms, and imposes three-year record-retention and disclosure duties on secondary-ticketing operators.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Regional consolidation and managed transition of conservation authorities
This schedule imposes a statutory amalgamation of named predecessor conservation authorities into eight new regional authorities effective on a prescribed transition date (default: Feb. 1, 2027). It creates transition committees, chaired by provincially-appointed project executives, to prepare transition plans that the new authorities must implement. The schedule carries assets, liabilities, employees and agreements forward to successor authorities, preserves employment continuity, deems many legal consequences to be non-disruptive (no change-of-control triggers, no automatic contract repudiations), and gives the provincial Agency and Minister power to issue directions during the transition period. Practically, that centralizes planning and gives the province control over timing, membership formulas (to be set by regulation), and the initial CAO appointments (the project executive serves as first CAO for two years).
Protect Ontario Account Investment Fund and removal of certain section 28 requirements
The Minister of Finance must establish the designated Protect Ontario Account Investment Fund to be used for provincial investments tied to innovation, infrastructure and strategic priorities; investment proceeds are returned to the fund unless the Minister directs otherwise. The schedule also repeals prior provisions that constrained transactions increasing Ontario’s indebtedness or contingent liabilities (section 28 provisions), while preserving continued application of earlier subsection 28(2) to transactions entered into before repeal. Several regulations that provided exceptions are revoked, moving discretion to the Minister and Lieutenant Governor in Council and reducing pre-existing procedural checks on contingent liabilities.
FOI operational reforms, staged access, privacy safeguards, and ministerial record exclusions
Provincial FOI rules shift many deadlines to business-day calculations and lengthen response windows (e.g., initial response periods to 45 business days). The head of an institution may propose phased delivery for complex requests and may extend time limits an additional time under enumerated circumstances. The Act adopts new data‑integration roles for the Chief Digital and Data Officer, requires privacy impact assessments and breach reporting/notification duties, and adds a significant carve-out: records in the custody or under the control of a minister or the minister’s office (and certain records under the Enhancing Digital Security and Trust Act, 2024) are excluded from FOI, with transitional rules and retroactive application to older records.
Short-term Crown borrowing authority up to $35 billion
This stand-alone Act authorizes the Lieutenant Governor in Council to issue orders permitting borrowings in any manner allowed under the Financial Administration Act up to a cumulative $35 billion to discharge indebtedness or meet payments charged to the Consolidated Revenue Fund. It is time-limited: no new orders may be made after Dec. 31, 2028, and borrowings under an order must be contracted by Dec. 31, 2029 unless specific agreements exist. The statute is an enabling, temporary fiscal instrument that expands the Crown’s borrowing headroom for budgetary flexibility.
Caps and transparency for secondary ticketing platforms
The amendments redefine secondary-market sales and impose a cap that prevents resale for more than the total price paid to the primary seller plus any platform fees, service charges and taxes charged by the secondary seller or operator. Operators must obtain proof of original purchase price before facilitating resale, disclose itemized fees and seller contact information, keep a ledger of each ticket offered or sold for at least three years, and may face regulated limits on permissible fees. The schedule also contains a non-entitlement-to-compensation clause removing claims arising from the schedule’s enactment.
Variable life benefits and related wind-up, transfer and death‑benefit rules
The Act authorizes a new pension form — variable life benefits — payable from a segregated fund within a pension fund whose payouts can vary with investment returns and pooled mortality. The schedule prescribes transfer rules, restrictions on contributions and inter‑fund transfers, an election process for members to move certain defined-contribution or voluntary amounts into a variable life benefit fund, and special partial-wind-up procedures and Chief Executive Officer powers to order partial wind-ups of the variable life portion. It also raises the PBGF non-guaranteed threshold in certain wind-up dates and provides for extinguishment processes for very old, unlocatable beneficiaries.
Block 18C development, repeal of Skydome bus-parking statute and litigation protections
This schedule removes the application of a City of Toronto by-law requirement for bus parking on block 18C, repeals the Skydome Act (Bus Parking), 2002, and authorizes regulations to terminate, suspend or amend contracts tied to block 18C development. It includes broad clauses extinguishing causes of action and barring a wide range of remedies against Crown and municipal actors for acts done under the schedule, while preserving judicial review and constitutional claims; it also disclaims entitlement to compensation except where regulations provide otherwise.
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
- Provincial government — gains expanded fiscal and programmatic tools (Protect Ontario Account and borrowing authority) and centralized control over conservation authority reorganization and related appointments, enabling faster, province-led project delivery.
- Secondary ticket purchasers — will see greater price protections on resale because platforms may not list tickets above the original total purchase price plus regulated fees, increasing predictability for consumers.
- Indigenous individuals registered under the Indian Act — are explicitly excluded from the Land Transfer Tax Act’s definition of “foreign national,” removing a tax classification barrier for registered Indians when purchasing land.
- Large employers and pension plan sponsors — receive new flexibility to offer variable life benefits and to manage long‑running unlocatable-beneficiary issues through the Chief Executive Officer consent process, potentially reducing long-term administrative liabilities.
- Consolidated regional conservation authorities — stand to gain operational scale, pooled resources and statutory continuity of contracts and liabilities immediately upon amalgamation.
Who Bears the Cost
- Municipalities and local stakeholders — lose some local discretion (e.g., conservation authority structure and watershed governance) and may face implementation costs associated with transition planning and reallocation of agreements.
- Heads of FOI institutions and municipal information officers — face broader procedural obligations (staged-access planning, privacy assessments, breach reporting) and longer response windows measured in business days, increasing administrative workload and compliance tasks.
- Secondary ticketing platforms and resale intermediaries — must implement proof-of-original-price verification, expanded disclosure and three-year record retention, and may face regulated limits on fees, increasing operational compliance costs.
- Ontario taxpayers — assume market and fiscal risk from both the Protect Ontario Account investments (ministerial discretion to retain or redirect proceeds) and up to $35 billion of borrowing authority if used.
- Pension plan members receiving variable life benefits — accept benefit variability tied to investment performance and mortality assumptions, which shifts some longevity and investment risk onto beneficiaries compared with traditional guaranteed defined-benefit payouts.
Key Issues
The Core Tension
The central dilemma is between provincial flexibility and speed versus local autonomy, transparency and risk containment: the province gains streamlined control to deliver major projects and fiscal initiatives quickly, but in doing so it concentrates decision-making, limits certain legal remedies and reduces immediate public access to information — creating trade-offs between efficient execution and democratic accountability that regulations and oversight will have to reconcile.
The Act intentionally shifts several policy choices from statute and municipal practice into executive discretion and regulations. The Conservation Authorities amendments transfer substantial decision-making to transition committees and the provincial Agency; although continuity clauses protect contracts and employees, the regulations will determine board composition, membership formulas and implementation timelines — creating litigation and political pressure points that are largely resolved by regulation rather than by the primary Act.
Separately, the Protect Ontario Account centralizes investment power under the Minister of Finance but leaves key governance and reporting details to regulation and ministerial direction, raising questions about transparency, accountability and how investment losses versus gains are treated in public accounts.
The FOI amendments introduce practical trade-offs: measuring deadlines in business days and allowing staged access can relieve front-line pressure on institutions, but the combined effect of longer working‑day deadlines, expanded extension grounds and the exclusion of ministerial-custody records reduces timely public access and judicially actionable remedies for certain records. The retroactive carve-out for ministerial records (deemed effective as far back as 1988) creates an unusual legal posture that may extinguish previously recognized access rights.
The bill also contains several provisions that limit remedies or bar compensation (for example, in the Bremner Boulevard and Ticket Sales schedules), narrowing recourse for affected parties and pushing disputes toward judicial review or constitutional claims only.
Pension reforms creating variable life benefits open product innovation but export investment and mortality risk to beneficiaries; the legislation creates complex transfer and wind‑up rules that will require new administration systems and regulatory guidance to avoid cross-plan asset commingling or unintended inequities. Finally, the Ontario Loan Act and the repeal of certain section 28 safeguards increase short‑term fiscal flexibility at the cost of reducing procedural checks on contingent liabilities — a shift that amplifies the need for rigorous reporting and oversight if the public is to evaluate fiscal risk prudently.
There's more to this law than the bill.
Codify Laws traces every connection across the legislative lifecycle.