Dear Minister Brison,

I am writing to offer the support of the Business Council of Canada for your department’s efforts to modernize Canada’s regulatory environment.

For decades, successive governments have worked to improve the way Canada develops and manages regulations, with the aim of protecting the public interest and supporting business competitiveness. Although there has been progress in some areas, significant gaps remain and seem likely to widen as technological advances stretch the capacity of regulators to respond effectively.

This past summer, we asked 61 of Canada’s leading companies about the competitiveness challenges they face. By a significant margin, survey participants said that the regulatory environment is the single most important policy factor affecting their investment decisions. Yet only 13 percent of them expressed a positive view of Canada’s current regulatory environment – a finding that we believe has important implications for economic growth and job creation. International rankings confirm that Canada is lagging in this area. The World Economic Forum, for example, ranks Canada 14th overall in its global competitiveness index, but in 38th place when it comes to the burden of government regulation.

Moreover, the challenges facing regulators and the companies they regulate are about to intensify. New technologies, products and business models—from autonomous vehicles and aerial drones to connected medical devices, wearables and the Internet of Things—bring with them difficult regulatory issues that, if mismanaged, could jeopardize Canada’s ambitions to be a global innovation leader.

As the Minister in charge of one of the most important agencies in the federal regulatory system, you have a unique vantage point and leadership role to play, both in reforming existing regulatory processes and in establishing forward-looking approaches to new developments.

For that reason, we were pleased to submit detailed comments on the draft Cabinet Directive on Regulation. In our submission we outlined ways to move from a stakeholder model that relies on episodic consultation to a model of true co-development – one that draws on industry expertise much earlier and throughout the process. We also urged the government to strengthen the capacity and challenge function of Treasury Board to ensure that departments follow the guidance set out in the Directive.

We look forward to providing additional input on the Directive and its associated policies in the coming months. We also intend to participate in the recently announced consultations on regulatory consolidation in the context of the Canada Free Trade Agreement. Our member companies have extensive experience with regulatory processes across Canada and internationally. They stand ready to share their insights and assist where needed.

Regulatory reform is hard work, but the potential benefits are substantial. Rather than being a drag on our economy and a disincentive to invest, our regulatory environment can be a driver of sustainable growth and inclusive innovation. I urge you to seize this opportunity.

I would look forward to discussing these issues in more detail at a time of your convenience.


John Manley