Canada Created 3 Agencies and a $25-Billion Fund in a Year. Here's Who Controls Them.

The Approval Layer

The Building Canada Act, enacted as Part 2 of Bill C-5, establishes a mechanism for the Governor in Council to designate projects as being "in the national interest" by adding them to a schedule. [1] Once a project is designated, Section 6(1) deems every determination, finding, and opinion required for an authorization to have been made in favour of permitting the project. [1]

The Act does not eliminate all legal obligations. Section 6(2) specifies that proponents are not exempt from measures they are required to take under existing enactments. Section 6(3) provides that an authorization is not to be granted solely on the basis of the deeming provision. But the structural effect is significant: for designated projects, the starting point of the review shifts from whether the project should proceed to what conditions apply to its construction. The Act creates a statutory presumption in favour of permitting designated projects, then channels federal authorizations into a single conditions document. [1] [2] [13]

The conditions document must include environmental protections and accommodation measures for Indigenous rights. The Act requires public consultation before designation, a 30-day Canada Gazette notice period, and public disclosure of the conditions document and reasons for any rejected recommendations. [1] [2]

The Act received Royal Assent on June 26, 2025, after an expedited passage. The House limited debate to two speakers per party per stage. Committee study was limited to two days. The Senate conducted a pre-study under a programming motion that required all votes by June 27. [11]

The layer of governance that previously took 3–5 years and involved multiple independent bodies that could each delay, condition, or deny a project has been replaced by a single ministerial instrument backed by a legislative presumption of approval. The review still happens; the outcome is now presumed.

The Delivery Layer

Within four months of the Building Canada Act becoming law, three new agencies were operational.

The Major Projects Office launched August 29, 2025, with Dawn Farrell, the former CEO of TransAlta, as its head. It serves as the single window for project proponents seeking federal regulatory approvals. The first set of projects under consideration for national interest designation was announced on September 11, 2025. [3] [10]

Build Canada Homes launched September 14, 2025, with Ana Bailão as CEO. A Special Operating Agency within Housing, Infrastructure and Communities Canada, it was capitalized at $13 billion and oversees construction on federal land sites, financing of affordable housing, and adoption of modular construction technology. Canada Lands Company, the Crown corporation managing federal real estate, was placed under its direction. [4]

The Defence Investment Agency was announced October 2, 2025, with Doug Guzman, the former Deputy Chair of RBC, as CEO. A Special Operating Agency within Public Services and Procurement Canada, it centralizes defence procurement for major acquisitions. His appointment was approved by the Governor in Council on October 1, one day before the public announcement. [5] [6]

Six months later, the Spring Economic Update proposed upgrading the DIA from a Special Operating Agency to a standalone entity with its own enabling legislation, expanded authorities under the Defence Production Act, and a dedicated cabinet minister. The update allocates $103.8 million over five years for the transition. The day before the update, Guzman told MPs that work was already underway to separate the agency from the procurement department, though he said he did not yet know whether it would become a Crown corporation or an independent agency. [14] [16]

All three agencies share a common structure: Special Operating Agencies, staffed through GIC appointments, reporting through ministerial oversight, with CEOs drawn from the private sector. All three were created through executive action rather than standalone legislation. And all three operate within the project pipeline that the Building Canada Act designates.

The Financing Layer

On April 27, 2026, Prime Minister Carney announced the Canada Strong Fund, the country's first sovereign wealth fund. The fund co-invests alongside private sector participants in projects deemed to be of national interest. It includes a retail investment product allowing individual Canadians to contribute savings. [7]

The Spring Economic Update, tabled the following day, disclosed the capitalization structure. The fund will receive an initial federal contribution of $25 billion over three years, on a cash basis. According to Globe and Mail reporting, that money comes from public debt, and the government does not list it as an expense that affects the deficit because it classifies the contribution as an asset. [14] [15]

The government says the fund will be an arm's-length Crown corporation with a CEO and qualified independent board. A dedicated transition office will finalize the fund's governance, investment mandate, and retail product design over the coming months. [14] The remaining test is legislative: appointment process, mandate constraints, ministerial direction powers, reporting rules, investment guidelines, and conflict safeguards. Until the enabling legislation is tabled, the structural independence of the fund is stated but not yet codified.

What is on the public record: the fund invests in the same project pipeline that the Building Canada Act designates, the Major Projects Office coordinates, and the capital budgeting framework funds. Since September 2025, the MPO has referred 15 projects representing over $125 billion in announced investment across nuclear, LNG, critical minerals, and transportation infrastructure. [14] The government is simultaneously the regulator, the project designator, the approver, the subsidizer, and now the co-investor.

The Appointment Structure

Every agency in this architecture is staffed through Governor in Council appointments. The PCO manages the process for approximately 3,400 GIC positions, spanning Crown corporations, agencies, tribunals, officers of Parliament, deputy ministers, heads of mission, and judges. The Prime Minister exercises constitutional prerogatives, formalized through a 1935 Order in Council, that include "determining the organization of government and recommending the appointment of the principal holders of public office." [8]

This is not unusual. GIC appointments are the standard mechanism for staffing federal entities, and they include due diligence, background checks, defined terms, compensation structures, and public accountability through parliamentary tabling. What is notable is the density of new appointment authority created in a compressed timeline: three new agency leadership positions plus the forthcoming fund, all within the same delivery chain, all created within ten months.

The DIA backgrounder notes that the agency's leadership approach is "consistent with those made to other recently created Special Operating Agencies, including the Major-Projects Office and Build Canada Homes, where leadership for these Agencies are sourced from the private sector." [12] The government treats this consistency as a virtue. The consistency is also the pattern this article documents.

The Architecture Compared

Canada's traditional governance architecture distributes authority deliberately. Parliament appropriates funds and sets mandates. Cabinet proposes policy within those mandates. Departments, led by career deputy ministers accountable to Parliament, implement that policy through regulatory bodies that operate on independent timelines. Environmental assessments, fisheries reviews, navigable waters determinations, Indigenous consultations, and sector regulators each have the authority to delay, condition, or deny a project. Treasury Board authorizes spending through the parliamentary estimates process. The Ethics Commissioner, the Auditor General, and the Parliamentary Budget Officer provide independent oversight.

This architecture is slow by design. The friction is the feature. Multiple veto points exist precisely so that no single actor controls the path from policy intent to capital deployment. A major project typically takes 3–5 years from proposal to approval.

The new delivery architecture compresses that path. The Building Canada Act creates a statutory presumption that designated projects should proceed and channels all federal authorizations into a single conditions document. Three agencies, each led by a GIC appointee, handle delivery across approvals, housing, and defence. A capital budgeting framework of $115 billion provides the fiscal envelope. A sovereign wealth fund deploys capital into the same pipeline the government designates and coordinates. The announced timeline from designation to delivery: two years. The observed timeline from legislation to sovereign wealth fund: ten months.

The oversight bodies retain their full mandates and legal authorities. The Ethics Commissioner can investigate conflicts as they arise. The Auditor General can audit spending. The PBO can publish independent costings and prospective fiscal analysis. Courts can hear challenges. Parliamentary committees can call witnesses. But much of the strongest independent scrutiny operates outside the approval instrument itself. The Auditor General audits after spending occurs; the PBO can analyze fiscal claims but does not approve projects; the Ethics Commissioner can investigate conflicts but does not sit inside the project-approval chain. In the distributed architecture, oversight was woven into the approval process. In the new architecture, it sits alongside it.