What we heard: Building Canada Strong For All

On this page

• Disclaimer
• Acknowledgements
• Executive Summary
• 1. Background and Context
• 2. About this Consultation
• 3. What We Heard
  • 3.1 Part I
  • 3.2 Part II
  • 3.3 Part III
  • 3.4 Sustaining the Wage Earner Protection Program to ensure its integrity
  • 3.5 Other potential changes to the Canada Labour Code that could help better support fair and safe outcomes for workers
• 4. Written Submissions Across Both Rounds of Consultations
• 5. Next Steps
• Annex A: Stakeholder Participants and Written Submissions
  • Round One Consultations April 17, 2026 - May 25, 2026
  • Round Two Consultations July 3, 2026 - August 2, 2026

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Disclaimer

This report summarizes perspectives shared during engagement activities on proposed legislative, regulatory, and policy changes related to Canada's federal labour relations framework. It is not intended to represent consensus, nor does it attribute views to any individual participant, community, organization, or government.

The information in this report has been organized thematically based on the proposals outlined in the Building Canada Strong for All - Powered by Canada's Building Workers spring and summer consultation documents. The ideas and views compiled in this report do not necessarily represent the views of the Government of Canada, except where otherwise indicated. Views are summarized collectively to protect confidentiality and to identify recurring themes; it should not be read as implying uniform views among First Nations, Inuit, and Métis governments, communities, or organizations, as well as stakeholders from labour representatives, employer representatives, or the general public.

Artificial intelligence (AI) tools [Copilot] were used to supplement government officials' analysis and to summarize responses to this engagement process. All content has been reviewed and validated by Government of Canada employees. For more information on how we use AI, please see our AI Strategy for the Federal Public Service 2025-2027: Overview.

Acknowledgements

The Government of Canada thanks all participants for sharing their time, expertise, priorities, and concerns. The perspectives shared throughout this engagement are essential to balance consideration of economic, environmental, Indigenous, and broader public interest benefits of major projects.

Executive Summary

The Government of Canada launched two rounds of consultations, in April and July 2026, to gather feedback from more than 100 unions, labour organizations, employers, employer associations and National Indigenous Organizations (NIOs). In total, 13 virtual roundtables were held, including two roundtables with national unions organized at their request and one ministerial roundtable led by the Honourable Patty Hajdu, Minister of Jobs and Families, and the Honourable John Zerucelli, Secretary of State (Labour). A total of 319 written submissions were received. The feedback received will help inform future policy directions to modernize Canada's labour relations framework and strengthen protections and supports for workers .

These consultations form part of the Government's commitment to Building Canada Strong for All by working to ensure that Canada's labour relations and workplace protection frameworks support workers, employers and a strong economy. With more than one million workers and over 22,000 employers operating under federal jurisdiction, ensuring our country has a modern, effective and balanced labour relations system is critical to protecting workers' rights, supporting productive workplaces and ensuring the continued success of industries that Canadians rely upon every day.

The Labour Program sought stakeholder input on a range of issues affecting labour relations and worker protections under the Canada Labour Code (Code). The spring consultation document examined opportunities to strengthen the collective bargaining framework, improve labour relations outcomes, and address issues that have been raised through stakeholder engagement, and previous reviews, such as the 2024 Industrial Inquiry Commission. The summer consultation document explored a number of issues in greater depth, including the role and use of section 107 of the Code, expedited grievance arbitration, wage theft and enforcement measures, as well as additional measures aimed at strengthening labour relations and better supporting workers.

In the two rounds of consultations, stakeholders were invited to provide views on a broad range of issues relating to collective bargaining, labour relations and worker protections, including:

• revising direct bargaining timelines
• revising conciliation and cooling-off periods
• revising strike and lockout notice requirements
• creating a special mediator role
• reviewing section 107 of the Code
• introducing expedited grievance arbitration
• addressing bad faith bargaining
• revising the duration of strike or lockout mandates
• facilitating first collective agreements
• extending successor rights in cases of contract retendering
• strengthening occupational health and safety protections
• improving labour mobility through harmonized training standards and regulations
• strengthening protections against worker misclassification and wage theft
• reviewing medical leave with pay provisions
• sustaining the Wage Earner Protection Program (WEPP)
• supporting workers affected by artificial intelligence and automation
• assessing bargaining approaches used in other jurisdictions
• other potential changes to the Code that could promote fair, safe and productive workplaces.

A key theme emerged consistently throughout both rounds of consultations: Canada's collective bargaining system is working well in most cases. Participants frequently noted that the vast majority (approximately 95 percent) of collective agreements are reached without a work stoppage and that collective bargaining remains the best mechanism for achieving durable workplace solutions. Accordingly, stakeholders generally favoured targeted and proportionate reforms rather than broad structural changes to the existing system, and stronger protections for workers.

Participants broadly agreed that collective agreements are best achieved at the bargaining table through good faith negotiations between employers and unions. Many stakeholders emphasized that any reforms should focus first on strengthening labour-management relationships, improving the conditions for successful bargaining, and providing effective support to parties before disputes escalate. There was broad support for enhancing the capacity and effectiveness of the Federal Mediation and Conciliation Service (FMCS) and the Canada Industrial Relations Board (CIRB) as key institutions that help parties reach negotiated settlements.

At the same time, many participants also recognized that the existing framework is unable to resolve highly complex disputes that can become prolonged and can have far reaching impacts. While these disputes represent a small proportion of bargaining relationships, they can have consequences that extend well beyond the parties at the bargaining table. In federally regulated sectors such as road transportation, ports, rail, and telecommunications, prolonged labour disruptions can have significant socio-economic impacts and public interest implications, notably on: workers, businesses, communities and the broader economy.

Views diverged considerably, on the role of government intervention in labour disputes. Some stakeholders have shown openness to the creation of additional dispute-resolution tools, and advocated for greater predictability, transparency and reliability regarding government engagement in labour disputes. Overall, employers argued that prolonged disruptions in key industries can have disproportionate impacts on economic growth, trade competitiveness, investment certainty and Canada's reputation as a reliable trading partner. They favoured measures that would help parties resolve disputes earlier and reduce the likelihood of prolonged disruptions. Employers also raised concerns regarding the medical leave with pay regime and advocated for changes to increase flexibility and address operational challenges.

"Canada needs a reliable method to resolve economically damaging labour disputes; one that respects the collective bargaining process, while avoiding disruptions that impair the national interest when negotiations fail. Other countries do this effectively. It can-and must-be done in Canada as well."

Labour organizations emphasized that free collective bargaining and the right to strike are fundamental rights that must remain at the centre of Canada's labour relations framework. While generally supportive of measures that strengthen bargaining relationships and help parties reach negotiated agreements, they expressed significant concerns regarding proposals that could prolong the bargaining process, infringe on workers' right to strike, or increase government intervention in labour disputes.

Many labour organizations identified the repeated use of the broad discretionary authority under section 107 of the Code as a significant concern. They argued that reliance on section 107 as a government intervention tool can create uncertainty for bargaining parties and weaken confidence in the collective bargaining process. In their view, the collective bargaining framework itself is generally functioning well. Rather, the challenge stems from the uncertainty associated with the potential for government intervention once bargaining reaches an impasse. Labour organizations consistently emphasized that efforts should focus on strengthening labour-management relationships and creating the conditions for parties to reach negotiated agreements at the bargaining table, thereby reducing the need for government intervention.

"To state that the Canadian economy cannot handle the economic disruption caused by (the very few) strikes in the federally regulated sector is to state that federally regulated workers should not have the right to strike at all."

Among the many collective bargaining measures discussed, labour organizations were particularly supportive of initiatives to facilitate first collective agreements and extend successor rights in cases of contract retendering. Unions and non-unionized worker representatives also stressed the importance of maintaining the current medical leave with pay regime as an important workplace health and safety protection.

With respect to worker protection measures, unions and employers shared many common objectives. Participants broadly supported stronger enforcement tools to combat worker misclassification and wage theft, enhanced occupational health and safety protections, including psychological health and emerging workplace risks, the harmonization of occupational health and safety training standards where appropriate, and improved training supports to help workers adapt to technological change. There was also support for measures to strengthen the long-term sustainability and effectiveness of the Wage Earner Protection Program (WEPP). Approaches to addressing these issues, however, often differed between employers and labour organizations.

Indigenous partners emphasized the importance of culturally responsive labour policies and workplace supports. Participants highlighted opportunities to incorporate Indigenous perspectives and practices into dispute-resolution processes, including culturally grounded approaches such as talking circles and elder involvement where appropriate. They also stressed the importance of maintaining essential services in Indigenous communities and ensuring that labour policies reflect the unique realities and needs of Indigenous workers, employers and communities.

The input received through these consultations will help inform the Government's policy direction as it considers opportunities to modernize Canada's federal labour relations framework and strengthen protections and supports for workers. While employers and labour organizations often held fundamentally different views on specific measures and the role of government in labour disputes, several common themes emerged. Participants generally emphasized the importance of protecting fundamental collective bargaining rights, supporting good faith bargaining, and strengthening the institutions and services that help parties reach negotiated settlements.

Views diverged most significantly on the appropriate response to complex labour disputes with broader economic or public interest impacts. Nevertheless, many participants emphasized that the primary objective should be to help employers and unions reach agreements at the bargaining table rather than rely on government intervention after disputes have escalated. The consultations also identified some interest in exploring targeted measures and dispute-resolution tools to help address the relatively small number of complex, high-impact disputes that can have significant consequences for workers, employers, communities and the broader public interest, while maintaining the integrity of the collective bargaining process.

Based on the input received through 13 roundtables and 319 written submissions through both rounds of consultations, the following issues emerged most consistently throughout the consultation process:

1. Background and Context

The Government has a clear and ambitious agenda to Build Canada Strong for All. With more than one million workers and over 22,000 employers operating under federal jurisdiction, ensuring our country has a modern, effective and balanced labour relations system that protects workers' rights, supports productive workplaces and ensures continued success of industries that Canadians and the Canadian economy is critical. At the heart of this ambition is building a resilient economy and workforce with a labour relations framework that reflects our country's modern-day challenges and opportunities. As such, these two rounds of consultations aim to accomplish this goal to ensure that Canada's labour relations and workplace protection frameworks support workers, employers and a strong economy.

While work stoppages remain relatively uncommon and 95 percent of all collective agreements continue to be reached through negotiation, these disputes have highlighted the significant impacts that can arise when bargaining challenges occur in critical sectors of the economy. This speaks to the strength of the collective bargaining process and the resolve of employers and employees to reach agreements at the table. However, in recent history, Canada has experienced high-profile labour disputes in federally regulated sectors, including at Canada Post, Air Canada, West Coast ports, major railways and WestJet. economy.

The concentration of major labour disruptions between 2023 and 2024 was particularly notable. During this period, Canada experienced two work stoppages at West Coast ports, simultaneous shutdowns at the country's major railways, and labour disruptions at the Port of Montreal. To understand the complexity of these disputes and to identify opportunities to strengthen labour relations, two Industrial Inquiry Commissions were struck pursuant to section 108 of the Code: one on Canada Post and the other on the West Coast Ports in British Columbia. The reports were both produced in 2025.

These events, together with the impact of widespread tariffs and global economic shocks that are affecting workers across sectors, prompted renewed discussion among governments, employers, unions and other stakeholders about how to ensure Canada's labour relations framework remains well equipped to support collective bargaining and address the most complex disputes.

Against this broader backdrop, the Government launched consultations to seek employer, union, Indigenous and other stakeholder perspectives on opportunities to modernize Canada's federal labour relations framework and strengthen worker protections and supports. The consultations examined a range of issues arising from stakeholder proposals, previous reviews, operational experience and challenges identified in the administration of the Code, including select recommendations from the Industrial Inquiry Commission on West Coast Ports. The objective was to inform potential policy directions that support good faith bargaining, strengthen labour relations institutions, improve outcomes for workers and employers, and ensure the framework is capable of addressing the complex disputes that can have broader economic and public interest consequences.

2. About this Consultation

During the consultations held throughout the spring and summer 2026, the Labour Program invited over 100 employers, employer representatives, unions and labour groups, and First Nations, Inuit and Métis governments and rights holders.

Thirteen virtual roundtables took place, consisting of joint employer-employee sessions and separate sessions with Indigenous partners, dedicated to potential changes to Part I (Industrial Relations), Part II (Occupational Health and Safety) and Part III (Labour Standards) of the Code, as well as potential amendments to the Wage Earner Protection Program Act (WEPPA) . Of the thirteen roundtables, two were held with national unions at their request, each attended by representatives of multiple bargaining units representing sectors from across the federally regulated private sector. A virtual ministerial roundtable was co-chaired by the Honourable Patty Hajdu, Minister of Jobs and Families and Minister responsible for the Federal Economic Development Agency for Northern Ontario, and the Honourable John Zerucelli, Secretary of State (Labour), to discuss key issues affecting federal labour relations and worker protections.

In addition, the Minister and Secretary of State met regularly with the Government-established Tripartite Advisory Council (TAC) to discuss emerging themes, gather advice, and exchange perspectives throughout the consultation process and following the roundtables. Established in March 2026, the TAC provides a trusted forum for dialogue, collaboration and consensus-building on federal labour and workplace issues. Its membership includes three labour representatives: Canadian Labour Congress, the Fédération des travailleurs et travailleuses du Québec and Unifor, as well as three employer-group representatives: Federally Regulated Employers - Transportation and Communications, the Conseil du patronat du Québec and the Business Council of Canada.

Stakeholders were also invited to provide feedback through written submissions in response to discussion papers released for both rounds of consultations. The Labour Program received a total of 319 written submissions from both targeted and unsolicited participants. These included submissions from 173 employer organizations, 74 labour organizations, 29 individuals, 2 parliamentarians or government representatives, and 41 other organizations and associations.

The Labour Program also reviewed unsolicited and late submissions, which accounted for 238 submissions across both consultation rounds. These submissions are summarized separately in this report.

While many stakeholders expressed concerns about the consultation timelines, noting that the timelines limited their ability to consult directly with their members and fully assess the proposals under consideration, the number, quality and substance of the feedback received remained high.

Some Indigenous partners indicated that their participation was intended to help inform broader discussions with their communities and rights holders. They emphasized that the perspectives provided were preliminary in nature, reflected their own organization's views, and should not be interpreted as representing all Indigenous peoples, communities or Nations, whose experiences, priorities and perspectives are diverse.

3. What We Heard

3.1 Part I

3.1.1 Revising the timelines for direct bargaining

Currently, the Code does not prescribe when parties must begin direct bargaining but allows them to begin as early as four months prior to the expiry of their collective agreement.

The Government sought feedback on requiring parties to begin direct bargaining within a specified amount of time before the expiry of their collective agreement to increase certainty within the collective bargaining timelines.

WWH from employer groups

Employers expressed mixed views on bargaining timelines, with some supporting earlier mandated commencement to reduce rushed negotiations and potential impasses, while others argued that the Code already allows sufficient flexibility and that existing timelines are too long, proposing a reduction from four months to 90 days and noting limited evidence that earlier notice shortens disputes. Opinions also differed on early involvement of the FMCS, with some advocating for its engagement at the outset to encourage interest-based negotiations and reduce reliance on last-resort interventions, while others opposed early intervention. There was, however, strong support for enhanced capacity for the FMCS as well as the CIRB. Additionally, there was some support for focusing on incentivizing good faith bargaining through greater transparency and by empowering conciliators and special mediators to report directly to the Minister.

WWH from employee groups

Nearly all unions and labour organizations opposed extending direct bargaining timelines, arguing that the current four-month period is sufficient, well established, and already longer than in most provinces, while emphasizing that parties can voluntarily begin earlier. Many contended that earlier timelines would not improve outcomes and instead pointed to reliance on government intervention as a key barrier, with one warning that mandating earlier bargaining could undermine the voluntary nature of the process, though a minority supported earlier timelines to reduce last-minute pressure and disputes.

"I would say that the right to bargain and a good, legitimate process to do so is itself in the national interest. I think that point has to be made very clearly."

Unions also called for stronger penalties for bad faith bargaining, improved CIRB capacity to avoid delays, and greater financial transparency to support more informed negotiations, while recommending that maintenance of activities proceedings not delay direct bargaining. Rather than extending timelines, many favoured enhanced early intervention by FMCS, including increased resources, although views differed on whether its involvement should remain voluntary.

WWH from Indigenous partners

An NIO supported extending timelines to begin direct bargaining earlier, noting that it could help facilitate agreements that include cultural leave provisions reflecting community responsibilities such as ceremonies and harvesting. They also indicated that earlier bargaining could support more constructive resolution of maintenance of activities agreements to prevent service disruptions on First Nation reserves, while easing capacity pressures on employers with small human resources teams.

3.1.2 Revising the conciliation and cooling off timelines

As part of the collective bargaining process, a conciliation period of up to 60 days-extendable by mutual agreement-allows FMCS conciliators to support parties in negotiating or revising a collective agreement. This is followed by a 21-day cooling off period, after which parties may acquire the statutory right to strike or lock-out.

The Government sought feedback on revising the 60-day conciliation period and 21-day cooling off period to support more effective good faith bargaining before strike or lockout rights are acquired.

WWH from employer groups

Employers expressed mixed views on extending bargaining timelines, with some maintaining that current conciliation and cooling off periods are sufficient, while others supported adjustments such as pausing conciliation upon reaching a tentative agreement to preserve time if it is rejected. Some favoured extending timelines, suggesting that more time be combined with structured mediation and public reporting-potentially involving special mediators-suggesting that this could improve settlement outcomes, particularly in high-impact sectors. Others called for greater flexibility, recommending that conciliators, mediators, and the Government have discretion to adjust mediation length based on circumstances, including models similar to the U.S. Railway Labor Act (RLA), where conciliators can oversee negotiations until satisfied with progress and provide recommendations to the Minister on resolving disputes.

WWH from employee groups

Unions and labour organizations generally opposed extending conciliation and cooling off periods, arguing that such changes would delay the right to strike and benefit employers without improving bargaining outcomes. They emphasized that current timelines are already longer than in most provinces and can be extended by mutual agreement, warning that unilateral extensions could encourage employers to delay meaningful negotiations. Some noted that lengthy timelines create practical challenges, such as requiring repeated strike votes due to expiry limits, prolonging uncertainty for workers, and undermining operational stability in sectors like ports. Alternatives proposed included shortening timelines, maintaining strike notice validity throughout bargaining, starting conciliation timelines at first contact rather than appointment, and, in some cases, reducing the cooling off period to avoid worker demobilization.

"An adjustment to conciliation or notice periods must not erode the practical right to strike or invite premature political intervention."

WWH from Indigenous partners

One NIO supported extending the conciliation and cooling off timelines if they could avoid service disruptions impacting those living on reserves.

3.1.3 Revising the timeline for notice of strike or lockout

The Code requires at least 72 hours' advance notice before commencing a work stoppage. Once a notice of strike or lockout has been issued, parties involved must prepare to shut down their operations in a safe and orderly manner.

The Government sought feedback on revising the 72-hour timeline.

WWH from employer groups

Most employers and employer organizations supported maintaining the 72-hour notice period as a minimum, emphasizing that large, geographically dispersed operations and critical supply chain sectors, such as rail, often require more time to safely wind down activities and comply with regulations, including those related to dangerous goods. While one employer opposed any changes, others advocated extending the notice period-some suggesting up to 10 days-to better manage logistical challenges and reduce disruption costs. Employers also cautioned that reducing or eliminating the notice period could pose risks to food and medical supply chains, particularly in rural and remote communities.

"We have shippers and customers who depend on rail, and we're not advocating to increase the 72 hours, but removing it would be at the detriment of Canadians, and at the detriment of what the Canadian Government is trying to do in terms of creating investment in Canada."

WWH from employee groups

Unions and labour organizations strongly opposed extending strike or lockout notice periods, arguing that doing so would undermine the purpose of strike action by reducing economic pressure on employers and shifting the balance of power in their favour. They emphasized that the current 72-hour notice is already among the longest in Canada, with some jurisdictions, like Ontario, requiring none, and that existing timelines are sufficient to pursue resolution and prepare for disruptions. While a few suggested the notice period could be shortened, many called for its full repeal, noting that maintenance of activities provisions and restrictions on replacement workers already address essential services and safety concerns, and that shorter or no notice would better preserve bargaining effectiveness and timely dispute resolution.

"Collective bargaining is best when the parties are focused on achieving a collective agreement, and that they have focused and clear timelines with which to achieve an agreement or to enter into a lawful strike or lockout period. And so, we would not support either an extension of this timeline or any further language which would make it somehow more mandatory."

WWH from Indigenous partners

The NIOs did not provide views on revising the timeline for notice of strike or lockout, but one noted that the organization does not endorse any infringement on workers' rights.

3.1.4 Creating a new special mediator role

Under the Code, the Minister of Labour may appoint a mediator at any time, either at the request of the parties or on the Minister's own initiative. The Minister can also ask a mediator to provide settlement recommendations. However, this authority has been used infrequently, and recommendations are typically not made public.

The Government sought feedback on a proposal to create a new special mediator role with additional authorities and a more structured role to support federally regulated parties in resolving labour disputes. In cases of unresolved disputes, the special mediator would provide the Minister with a report (also provided to the employer and union), providing an assessment of the negotiations, the likelihood of achieving an agreement within a reasonable timeframe, and recommendations. The Special Mediator's report would also be made public to enhance transparency and encourage good faith bargaining.

WWH from employer groups

Nearly all employers were supportive of introducing a special mediator under the Code. They argued that a special mediator could provide an additional, neutral tool to ensure that parties are engaged at the bargaining table and increase the likelihood of reaching a negotiated agreement by creating an incentive to avoid special mediator being appointed. A few employers and employer organizations also emphasized the economic impact of recent labour disputes and suggested that once appointed, a special mediator could help parties reach agreements and avoid further disruptions. They also suggested that a special mediator's public report could hold both parties accountable and increase transparency.

"We want mechanisms and tools that help the parties stay at the table and reach collective agreements. We're looking for ways to incentivize the parties to negotiate, in good faith, a collective agreement [...] In most cases the current framework under the Canada Labour Code works very well. But when bargaining becomes entrenched in supply chain-critical sectors, the consequences extend well beyond just the parties. In those situations, the current system does not provide enough structure to help resolve impasses before they escalate."

A few employer organizations supported providing special mediators with the authority to make recommendations and publicly report on unresolved issues or the status of negotiations. One employer organization also suggested that the Minister should have the power to impose a special mediator's recommendations and that the special mediator should be able to encourage parties to withdraw certain bargaining positions. Several employers recommended that bargaining timelines should be paused during the appointment of the special mediator to ensure their work could be completed before a strike or lock-out could be actioned.

One employer recommended that a special mediator should be appointed at the request of the parties or at the Minister's discretion at or near the close of conciliation or during cooling off. The employer suggested that the process should take at least 60 days, with two weeks for the special mediator to prepare a report that would be made public. They also noted that the right to strike and lockout should be suspended during special mediation.

Similarly, one employer association proposed that a special mediator be appointed following conciliation and, for disputes affecting critical supply chains, on a mandatory basis. The association suggested that special mediators should have the authority to compel the production of relevant information, issue recommendations respecting settlement terms, and publicly report on outstanding issues where bargaining remains at an impasse. It also indicated that strikes and lockouts should be suspended while the special mediation process is underway.

One employer association proposed a mediator-arbitrator model in which a neutral third party would be involved from the outset of negotiations and could transition from mediation to final and binding arbitration if the parties are unable to reach an agreement.

A few employers and employer organizations suggested that the use of special mediators should be targeted to specific sectors, particularly transportation-related sectors and industries critical to national supply chains, with some recommending that the process be mandatory in such cases.

WWH from employee groups

Many unions and labour organizations offered some qualified support for a special mediator under specific conditions.

Most unions and labour organizations were strongly opposed to the creation of a new special mediator role if it added time to the bargaining process or infringing on the right to strike. They also expressed concern that a special mediator's report could form the basis of an imposed collective agreement or arbitration. A few unions shared concerns that the introduction of a special mediator could lead employers to avoid negotiating in good faith and suggested the terms of reference and public nature of the report be negotiated by both parties.

"The concern about the special mediator proposal is not, from our side, that we are opposed to expert mediation assistance at the bargaining table to assist the parties at reaching an agreement. The concern is that the special mediator will ultimately have the power to write a report and that report will become the basis for an imposed collective agreement."

A few unions suggested that existing tools under the Code, such as conciliation boards and conciliation commissions, should be better leveraged instead of introducing new roles.

Many unions and one labour organization were opposed to the creation of a special mediator role that could share similarities with the U.S. Railway Labor Act, which provides that the President may impose an emergency board and delay the right to strike.

At the same time, many unions and labour organizations offered some support for a special mediator if it did not lengthen timelines and did not suspend the right to strike. If a special mediator did proceed, many unions supported ensuring that a special mediator's report be made public to enhance transparency.

Alternatively, a few other unions suggested that the report should not be made public, arguing that this could lead to mistrust and undermine the special mediation process and neutrality. They suggested the report should only be disclosed with the consent of both parties and not include confidential bargaining information.

One union suggested that a special mediator, within limits, could be a practical tool to advance free collective bargaining. They argued that a special mediator with direct knowledge of the specific industries could help parties at the bargaining table if the person had real powers to compel participation and production of documents and became involved early in the process. They suggested that the special mediator should be an expert third party (distinct from the FMCS) and that British Columbia's Labour Relations Code could be used as a model.

One union suggested that the special mediator should be selected by both the employer and the union. A few of the unions stated that a special mediator should only be voluntary and available on the parties' mutual request, with termination possible at any time by either party. A few other unions also proposed that the appointed special mediator be time-limited, with some suggesting a 30-day cap for the entire mediation process and consent from both parties.

WWH from Indigenous partners

One NIO was supportive of introducing a special mediator role; however, they emphasized that a special mediator should only be introduced at the beginning of the bargaining process and should not delay the statutory right to strike or lockout.

3.1.5 Reviewing section 107

Section 107 of the Code allows the Minister to do what is necessary to maintain or secure industrial peace and promote the settlement of disputes, including referring questions to the CIRB, or directing the CIRB to take actions the Minister deems necessary. In recent years, in a few exceptional cases, Ministers have directed the CIRB to order that operations and duties resume, impose binding arbitration, and/or extend the terms of the collective agreements.

The Government sought stakeholder feedback on section 107 and its use in maintaining or securing industrial peace and promoting conditions favourable to dispute settlement.

WWH from employer groups

Employers and employer organizations generally supported retaining section 107 or a comparable dispute resolution mechanism. While emphasizing that negotiated agreements at the bargaining table remain the preferred outcome, many employers argued that additional intervention tools may be necessary to address rare but complex disputes with significant economic, national, or public impacts. This view was particularly prevalent among stakeholders in critical supply chain sectors, where work stoppages can have far-reaching consequences for workers, businesses, consumers, and the broader economy.

Some employers noted that, in the absence of section 107, the Code provides limited mechanisms to respond to disruptions affecting national supply chains. To improve predictability and confidence in the use of such measures, employers suggested establishing clearer criteria or economic thresholds for intervention, expanding protections for key commodities and transportation networks, creating consequences for non-compliance with orders, and using special mediator reports to help inform decisions and support timely responses to bargaining impasses.

"There is a right to strike in Canada, and it is not our intention to undermine that right. We agree that it exists, we agree that it has been supported by the Supreme Court. But we do think it's reasonable to acknowledge that there are some limited exceptions to a right to strike. It is not absolute."

Additional perspectives provided by employer groups in the second round of consultations

Many employers emphasized that section 107 is a reactive mechanism and recommended introducing more proactive tools to support dispute resolution and collective bargaining before government intervention becomes necessary.

A few employers and employer organizations argued that section 107 should retain its flexibility as a residual or contingency power to address unforeseen labour disputes and circumstances where government intervention may be required. They cautioned that additional restrictions or prescriptive rules could limit the Minister's ability to respond effectively when the national interest is at stake.

A few employers and employer organizations suggested clarifying key concepts in the Code, including the circumstances under which section 107 may be used and the meaning of industrial peace, with some proposing that these concepts explicitly recognize the national interest and supply chain continuity.

Many employers suggested that a special mediator should have the authority to temporarily suspend statutory bargaining timelines where meaningful negotiations remain possible or where an unresolved bad faith bargaining allegation could affect the bargaining process.

One employer association recommended granting the federal Cabinet explicit authority to impose binding arbitration where collective bargaining has failed, a special mediator's report has been issued, and a significant threat to the public interest has been identified.

WWH from employee groups

Nearly all unions and labour organizations called for repealing or amending section 107, arguing that its use undermines the constitutional right to strike and weakens collective bargaining by removing union leverage and encouraging employers to hold out for government intervention. They emphasized that the vast majority of agreements are reached without work stoppages or government intervention and expressed concern that section 107 has been misinterpreted or overused, specifically to end strikes and lockouts and impose binding arbitration, often in situations that do not pose risks to public health or safety. Many also argued that its use damages labour relations, increases frustration among workers, and reduces democratic oversight when compared to back-to-work legislation.

"We continue to have employers attempting to imply that the national interest of Canadians aligns solely with their continued business operation. Of course, that's partially true, but also what's in the national interest of Canada is good jobs that evolve through collective bargaining, and that collective bargaining must be free and fair and absent intervention."

They raised concerns about arbitration outcomes imposed through section 107, citing a lack of sector-specific expertise and a tendency toward status quo decisions that hinder progress on new worker protections. Many recommended adding stronger guardrails-such as mandatory justification, prior consultation, exhaustion of other tools, and public reporting-or limiting its scope to referrals to the CIRB. Others cautioned against expanding its use amid ongoing Charter challenges and warned that relying on FMCS reports or directing the CIRB to resolve disputes could undermine the perceived independence and credibility of these institutions.

"The greatest instability, in our opinion, has been caused by the frequent use of section 107, disincentivizing employers to come to the table and bargain. If collective bargaining is flailing hopelessly, it's likely because one side doesn't want to bargain, because they know that they're going to have government intervene and bail them out of their responsibility under the Canada Labour Code to engage in collective bargaining in good faith to attain a collective agreement."

Additional perspectives provided by employee groups in the second round of consultations

Many unions argued that Charter-protected collective bargaining and the right to strike are themselves in the public interest and should continue to be upheld, including during periods of economic or geopolitical uncertainty. A few unions pointed to Canada's international labour obligations and developments in international labour law, arguing that government intervention to end work stoppages is inconsistent with protections for freedom of association and the right to strike.

One employee association suggested that, if section 107 is retained, its use should be One employee association suggested that, if section 107 is retained, its use should be limited to cases involving clear evidence of bad faith bargaining, refusal to enter into a collective agreement, or substantiated unfair labour practices. Another union recommended strengthening existing dispute resolution mechanisms under the Code, including greater use of conciliation commissioners and conciliation boards, as an alternative to intervention under section 107. Another union suggested that a well-resourced FMCS, supported by experienced mediators and a special mediator serving only a facilitative role, could reduce the need for section 107 interventions.

Many unions voiced opposition to creating a new public-interest process, arguing that similar processes have delayed collective bargaining in other jurisdictions. One union opposed the use of public reports or independent assessments of bargaining impasses, arguing that information on negotiations should remain with the parties and the FMCS and that public reporting serves little labour relations purpose.

Another union suggested that the CIRB should operate with greater independence from the Government to strengthen confidence in the collective bargaining system.

WWH from Indigenous partners

Although one NIO expressed concerns regarding the use of section 107 to limit workers' rights, they also acknowledged that its use could be necessary to avoid essential service disruptions or prevent prolonged disruptions in critical sectors.

Additional perspectives provided by Indigenous partners in the second round of consultations

One NIO expressed concerns with section 107 being used as a means to limit the rights of Indigenous employees to exercise their right to strike. Another NIO suggested that section 107 should only be used as a means of last resort when all other mechanisms have failed, including attempts at good faith bargaining, mediation and voluntary arbitration.

3.1.6 Assessing examples of bargaining approaches from other jurisdictions

Alternative models for structuring collective bargaining exist across provinces, territories, and international jurisdictions.

The Government sought feedback on some of these models, such as geographic certification and sectoral bargaining arrangements, as well as essential services designations.

WWH from employer groups

Most employers and employer representatives generally supported geographic certification at the West Coast ports, asserting that it could help stabilize supply chains and promote Canada's position as a reliable trading partner.

"Geographic certification for BC ports, we see that as a critical step that is needed to support collective bargaining and support stability at the ports on the western coast of Canada […] Several years later [following 2023 and 2024 work stoppages], that traffic has not returned. Given the economic circumstances that we find ourselves in, the trade and tariff landscape with our biggest trading partner, we cannot afford that as a country to go through such disruption again."

Many employer representatives noted that geographic certification would bring the West Coast ports in alignment with other ports across Canada and formalize the existing voluntary relationship between the parties. One employer organization emphasized that geographic certification would promote greater stability and predictability throughout Canada's transportation supply chains and support Canada's reputation as a reliable trading partner. Two employer representatives suggested the CIRB should be permitted to certify longshore workers in a single geographic certification, on the application of employers or on referral by the Minister.

Many employers argued against sectoral bargaining for their respective industries (i.e., aviation, rail and telecommunications), arguing that it would undermine competitiveness, reduce flexibility, and increase the likelihood and scale of simultaneous disputes. A few employer representatives and one employer noted that sectoral bargaining would only be beneficial within certain industries, such as those that assign work through hiring halls/shared labour pools (i.e., longshoring). They noted that in other industries, sectoral bargaining could create operational and legal challenges.

"Our point throughout the accelerated consultation has been that the system under Part I works and does not need a massive overall. We need to address critical supply chain shutdowns and the national interest."

While requests for essential service designation was not broadly advanced, one employer organization indicated that a majority of its members were in favour of designating services within supply chain industries as essential services. They noted that the downstream impacts of work stoppages are shouldered by small businesses and third parties. One employer suggested that the maintenance of activities framework under the Code be expanded to apply to labour disputes that could impact national economic stability, or to certain sectors, such as telecommunications. However, other employer representatives opposed an essential service designation as it was seen as unconducive to healthy labour relations.

WWH from employee groups

Many unions and labour organizations were not opposed to alternative bargaining structures in principle, but emphasized that such approaches should be voluntarily pursued by the parties and not be imposed by the Government. A few unions argued that geographic certification would not be a structural solution for poor bargaining relationships and that this measure is successful in some areas and not others, suggesting the real solution was ensuring the right parties were at the table and ready to bargain. Another union suggested that geographic certification could reduce bargaining costs by centralizing bargaining at a single table. A few unions suggested that there was insufficient time to properly consider these measures in the current consultation.

Many unions and labour organizations supported voluntary multi-employer and sectoral bargaining as a way to strengthen unionization, improve working conditions, and increase bargaining power, particularly in fragmented industries such as telecommunications and in Northern or remote communities. They emphasized that such models should be inclusive of all workers, including gig and dependent contractors, and complement rather than replace enterprise-level bargaining. Some suggested targeting sectors with low union density and limited access to collective bargaining, drawing on models like New Zealand's Fair Pay Agreements, and recommended further study or formal inquiry into sectoral approaches. However, one union opposed sectoral bargaining, arguing that company-level negotiations better reflect industry-specific operational differences.

Many unions and labour organizations argued that maintenance of activities agreements should be strictly limited to protecting public health and safety and not be expanded to include broader considerations such as economic security, warning that such changes would infringe on the right to strike, upset the balance of bargaining power, and lead to increased litigation. They expressed concern that the current process is sometimes misused by employers to delay negotiations and pointed to delays at the CIRB due to resource constraints as a more pressing issue. Unions also opposed designating workers or workplaces as "essential," viewing it as unconstitutional, and rejected any shift of decision-making authority away from the CIRB to political actors. Some proposed alternatives, such as triggering binding arbitration if essential service designations were to be introduced and would cover a broad fraction of the workplace, while others emphasized the need for clearer processes, adequate resourcing, and careful consideration of broader labour reforms through more comprehensive consultation.

WWH from Indigenous partners

One Indigenous partner expressed that sectoral bargaining would limit the flexibility of firm-level negotiations and pose challenges for smaller employers unable to provide the same baseline terms and conditions of employment as larger employers. They suggested a Fair Pay Agreement model to support the mutual determination of interests.

They also supported bargaining models that could be more culturally specific to Indigenous groups, such as talking circles, which are grounded in mutual respect and consensus building. Additionally, the involvement and compensation of Elders and knowledge keepers in the dispute resolution process would lend a culturally sensitive lens and promote good faith bargaining.

3.1.7 Introducing expedited grievance arbitration provisions

The ability of bargaining parties to resolve grievances is integral to strong labour relations. However, some parties have a significant backlog of outstanding grievances.

The Government sought feedback on the introduction of expedited grievance arbitration provisions to help support the timely resolution of grievances and avoid grievance backlogs between parties during the term of a collective agreement.

WWH from employer groups

Employers expressed mixed views on expedited grievance arbitration. Some supported introducing new measures to improve timeliness, provided new measures would not override existing grievance processes already established in some collective agreements or add additional layers of complexity. Others opposed new provisions altogether, arguing that expedited mechanisms already exist in some agreements and that additional requirements are unnecessary and may fail to address underlying issues. Concerns were also raised about allowing unilateral access to expedited arbitration, with suggestions that its use should require mutual agreement or be subject to arbitrator discretion. Additionally, some employers noted that delays in grievance resolution are more often due to limited arbitrator availability than procedural barriers, and pointed to the need for additional capacity.

Additional perspectives raised by employer groups in the second round of consultations

A few employer associations argued that any expedited grievance arbitration mechanism should be voluntary, tailored to the bargaining relationship, and subordinate to procedures negotiated in collective agreements. A few employers and employer associations emphasized that expedited processes may not be appropriate for all disputes and suggested that arbitrators should have discretion to decline expedited proceedings where grievances are too complex and instead refer them to the regular arbitration process.

One employer recommended requiring the consolidation of multiple grievances arising from the same alleged violation into a single group or policy grievance where a common issue affects numerous employees. Another employer recommended maintaining a roster of experienced arbitrators in federally regulated sectors to improve access to specialized expertise and streamline appointments.

WWH from employee groups

"When you're going into a round of bargaining with hundreds of grievances in the queue, with 20, 30, 50, 60 terminations that you're trying to address with your membership, you're laying the seeds of a round of bargaining that's going to be very difficult to succeed, very difficult to ratify, and more than likely is going to fail."

Nearly all unions and labour organizations supported introducing expedited grievance arbitration to enable faster resolution and reduce backlogs, noting that delays-often caused by limited arbitrator availability-can lead to hundreds or even thousands of unresolved grievances and create pressure during bargaining. Some argued that employers may deliberately delay grievance handling, further compounding the issue. They emphasized that any new expedited process must be supported by sufficient resources, including a larger pool of trained arbitrators and should complement-not replace-existing grievance procedures in collective agreements, recognizing that not all cases are suitable for expedited handling.

Unions recommended that expedited arbitration be accessible and flexible, including the ability to initiate the process unilaterally without restricting strike rights, with a single arbitrator selected from a joint panel and supported by clear, efficient procedures such as issue narrowing, pre-hearing disclosure, and limits on evidence. Unions also supported screening mechanisms to direct complex cases to full arbitration, greater use of alternative dispute resolution, and an expanded role for the FMCS. Additionally, one union suggested using section 108 of the Code to formally examine grievance backlogs and identify broader systemic improvements to labour relations.

Additional perspectives raised by employee groups in the second round of consultations

A few unions recommended modernizing the Code by incorporating expedited grievance arbitration models used in other jurisdictions, pointing to British Columbia and Ontario as examples of a more efficient arbitration process and suggested that similar timelines could help reduce grievance backlogs in the federal sector

A few unions also emphasized that expedited arbitration should be reserved for priority, routine, or lower-complexity matters, while more complex disputes should continue through the regular arbitration process. Another union recommended that grievances involving discharge or termination be subject to enhanced expedited procedures given their potential impact on employees.

One union also expressed concern that expedited grievance processes may be resource-intensive for smaller unions, which may have fewer resources than employers to participate in accelerated proceedings.

WWH from Indigenous partners

The NIOs did not provide views on expedited grievance arbitration.

3.1.8 Extending successor rights in cases of contract retendering

The Code requires that union representation and collective agreements be preserved when businesses are sold, transferred, leased or otherwise disposed of, but this protection does not extend to contract retendering. Instead, subsection 47.3(2) of the Code ensures that, when a service contract changes hands, affected employees are not paid less than employees of the previous contractor who provided the same or substantially similar services.. Part III of the Code, however, protects employees’ entitlement to certain labour standards (e.g., paid leaves, severance pay).

The Government sought feedback on contract retendering to potentially strengthen Part I protections, including whether successor rights should be extended to contract retendering.

WWH from employer groups

Employers were generally not opposed to successor rights within limits, noting that contract retendering is relatively rare in the federally regulated private sector and concentrated in specific industries, such as the airlines. Some recommended restricting successor rights to sectors where operational continuity and safety are critical, while others emphasized the need for mandatory disclosure in retendering processes to improve transparency for bidders and workers. However, concerns were raised that extending successor rights more broadly could reduce flexibility in vendor selection, increase costs, and discourage competition, with some employers arguing that existing protections are sufficient and additional provisions would unnecessarily constrain contracting and restructuring decisions.

WWH from employee groups

Most unions and labour organizations strongly supported extending successor rights to contract retendering to provide workers with continuity and stability by preserving collective agreements across contracts. They noted that, unlike business sales, current federal rules often do not protect workers in retendering situations, creating inconsistency compared to jurisdictions such as Ontario and British Columbia. Without protections, unions face added legal costs and effort to maintain bargaining rights, while workers may experience declining wages and conditions, particularly in sectors like aviation where retendering can drive a "race to the bottom." Concerns were also raised about impacts on workforce quality and public safety when experienced workers are replaced by lower-cost, less experienced staff.

Unions argued that a clear and robust successor rights regime would strengthen labour stability, reduce litigation, and prevent contract flipping from undermining unionized work. Many recommended expanding successorship rules to ensure all wages, benefits, and workers are retained across contracts and applying these protections broadly across federally regulated sectors facing similar challenges. Additional proposals included preventing contract structures designed to evade successor obligations, introducing advance notice requirements in sectors like airlines, and leveraging federal funding or property agreements to promote fair wages, such as through living wage policies.

"I have 500 members who are going to be without a job as of June 1^st […] We had just successfully bargained them a contract that had fantastic wages that they could actually feed their families on and not have to have 3 jobs. And the next thing we know, the contracts come around again for the licenses, and they are not the lowest bidders, so they are one of the ones that are thrown to the wolves. So now […] they're starting back down at minimum wage, when they were making $32 an hour."

WWH from Indigenous partners

The NIOs did not provide views on successorship rights in instances of contract retendering.

3.1.9 Additional Part I Measures Explored in the Second Round of Consultations

3.1.9.1 Addressing bad faith bargaining

During the initial consultation period, employers and unions agreed that the best deals are reached at the bargaining table. Similarly, both employers and unions indicated that bad faith bargaining can affect parties' ability to reach agreements at the bargaining table. Many also emphasized the importance of introducing tools to support good faith bargaining through potential incentives and/or penalties.

The Government sought further engagement with stakeholders on how it could better promote or incentivize good faith bargaining and encourage constructive engagement between bargaining parties.

WWH from employer groups

Many employers and employer organizations stressed the importance of good faith bargaining and supported stronger measures to encourage meaningful engagement at the bargaining table, including enhanced remedies, penalties, compliance mechanisms, and, in one case, making fulfillment of good faith bargaining obligations a prerequisite to obtaining the right to strike or lockout. Some also supported financial penalties or other proportionate consequences for substantiated cases of bad faith bargaining, provided safeguards exist to prevent frivolous or vexatious complaints from being used as bargaining tactics.

Several employers expressed concern that existing processes for addressing bad faith bargaining are not sufficiently timely or effective, noting that delays in CIRB proceedings can enable tactical misconduct and undermine collective bargaining. They advocated for more proactive and expedited approaches, including greater clarity and transparency in the CIRB's handling of complaints and expedited processes for allegations arising near strike or lockout deadlines. Some also recommended a stronger role for third parties, such as FMCS conciliators or special mediators, in assessing bargaining conduct and promoting transparency and accountability. One employer, however, maintained that the current provisions of the Code are sufficient and opposed introducing additional measures.

WWH from employee groups

Many unions and employee groups expressed concern about delays in CIRB proceedings and emphasized the need for sufficient resources and expedited processes to ensure the timely resolution of unfair labour practice and bad faith bargaining complaints, including disputes over access to information relevant to collective bargaining. Many argued that employer conduct, rather than shortcomings in the Code, is often responsible for delays and instances of bad faith bargaining, while a few suggested that the possibility of government intervention under section 107 may reduce incentives for parties to reach negotiated settlements.

Views on financial penalties for bad faith bargaining were mixed. Some unions opposed specific fines, arguing that existing remedies are sufficient and that fixed penalties could have disproportionate impacts, and instead supported procedural safeguards to address repeated frivolous complaints. Others supported financial consequences, although one union suggested that findings of bad faith bargaining and existing remedies may be stronger deterrents than fines. Additional proposals included treating unsupported demands to remove negotiated rights or monetary entitlements as evidence of bad faith bargaining, while preserving evidence-based concession bargaining, and introducing measures to support bargaining and dispute resolution, such as longer notice to bargain periods, bargaining timelines, mandatory mediation before filing a notice of dispute, and early FMCS involvement in certain bargaining relationships.

WWH from Indigenous partners

One NIO recommended that allegations of bad faith bargaining be reviewed by an impartial third party responsible for assessing the bargaining relationship and determining appropriate resolutions. Moreover, they recommended that any administrative penalties should be proportionate to the size of the organization.

Another NIO suggested a culturally supportive lens in the collective bargaining process could promote good faith bargaining. They also indicated that elders and knowledge keepers should be compensated if/when they are appointed to support negotiations, similar to the compensation of a special mediator and that the appointment of a special mediator should not delay the statutory right to strike or lockout.

3.1.9.2 Length of Strike or Lockout Mandate

As part of the legal requirement to issue advance notice of a strike or lockout, a union must, pursuant to subsection 87.3(1) of the Code, receive a strike mandate through a secret ballot vote or, in the case of employers' organizations, a lockout mandate through a secret ballot vote pursuant to subsection 87.3(2). Strike or lockout mandates are valid for 60 days. If a strike or lockout does not occur within the 60-day period, a new secret ballot vote is required.

During the initial consultation period, some stakeholders raised concerns regarding the validity period for strike mandates, with some suggesting that strike votes remain valid throughout bargaining and not be retaken every 60 days.

The Government sought stakeholder feedback on potentially revising the 60-day validity period to incentivize better outcomes at the bargaining table.

WWH from employer groups

Employers and employer associations generally supported maintaining a time-limited validity period for strike and lockout mandates. A few employer associations supported retaining the current 60-day validity period, arguing that it promotes accountability and avoids uncertainty associated with outdated mandates.

A few employers and employer associations suggested that the validity period should be shortened or that strike mandates should be renewed during prolonged disputes. They argued that long validity periods may encourage pre-planned strike activity, reduce incentives to continue bargaining, and weaken accountability to employees and stakeholders.

WWH from employee groups

Many unions supported extending the validity period of strike mandates beyond the current timeframe, with some recommending that strike mandates remain in effect for the duration of collective bargaining. They argued that the current validity period is unnecessarily short, creates administrative burdens, and can require repeated strike votes during lengthy negotiations.

A few unions specifically supported eliminating the 60-day validity period, while another union proposed that strike or lockout mandates remain valid until a first or renewed collective agreement is reached, or alternatively remain valid for four months - arguing that renewing mandates can be time-consuming, complex, costly, and burdensome for organizations with limited resources.

WWH from Indigenous partners

One NIO supported extending the length of a strike mandate to apply for the duration of the collective bargaining cycle but acknowledged that there may be other relevant perspectives from unions.

3.1.9.3 First collective agreements

During the initial consultation period, some unions highlighted challenges with negotiating first collective agreements, including encountering delays, impasses and difficulties in establishing effective relationships. They raised that the first collective agreement sets the tone for future negotiation between parties and as such, sets the tone for labour relations.

The Government sought stakeholder feedback on what additional measures, if any, are needed to support parties in reaching first collective agreements.

WWH from employer groups

A few employers and employer associations supported measures to facilitate the successful negotiation of first collective agreements and foster constructive labour-management relationships from the outset. They viewed enhanced mediation, including the use of special mediators, as a valuable tool for narrowing issues in dispute, supporting meaningful bargaining, and reducing reliance on imposed settlements.

Some employers also advocated for earlier FMCS involvement in first collective agreement negotiations, arguing that structured mediation is most effective before bargaining positions become entrenched. They proposed allowing parties to access conciliator support during direct bargaining without filing a notice of dispute or formally entering conciliation. One employer further recommended requiring unresolved first collective agreement disputes to proceed to interest arbitration following conciliation and mediation, rather than permitting strikes or lockouts.

WWH from employee groups

A few unions supported reforms to first collective agreement arbitration, arguing that existing mechanisms can be difficult to access and that first agreements can be particularly challenging to negotiate. They supported allowing unions to initiate arbitration and suggested examining first contract arbitration models used in other jurisdictions, including Quebec, British Columbia, and Manitoba.

A few unions recommended reducing ministerial discretion in first collective agreement disputes by providing more direct or automatic access to mediation and arbitration. One union suggested that access should be based on defined statutory triggers, while another recommended a no-fault approach to first contract interest arbitration.

A few unions also supported earlier involvement of FMCS in first collective agreement negotiations and suggested that FMCS assistance should be available at the request of either party once bargaining has begun.

Many unions emphasized the need for additional FMCS resources, staffing, training, and sector-specific expertise to better support collective bargaining and the negotiation of first collective agreements.

WWH from Indigenous partners

One NIO suggested that culturally sensitive support and ceremonies be available to bargaining parties to assist during negotiations (e.g., sweat lodge).

3.1.10 Other potential changes to Part I of the Canada Labour Code that could help better support fair and safe outcomes for workers

WWH from employer groups

Employers and employer organizations emphasized the need to protect the national interest in labour disputes affecting critical supply chains and transportation, advocating for alternative dispute resolution mechanisms such as mediation-arbitration models that combine ongoing mediation, recommended settlement terms, and binding outcomes if agreements are not reached.

One employer organization also proposed establishing a dedicated statutory mechanism for government-directed final binding arbitration in exceptional circumstances where work stoppages threaten critical supply chains or could result in significant national economic harm. They proposed stronger enforcement tools, including mandatory compliance mechanisms, fines, and greater transparency through public reporting by neutral third parties.

Some suggested procedural changes, such as delaying maintenance of activities agreements until impasse, empowering the FMCS to remove non-negotiable issues, and adopting elements of the U.S. Railway Labor Act model where mediators assess when negotiations are no longer productive. Additional proposals included reversing the ban on replacement workers, clarifying consequences for non-compliance with ministerial or CIRB orders, and reinforcing good faith bargaining obligations before parties can proceed to strikes or lockouts.

One employer association recommended expanding the current protections for grain movement under the Code to cover all commodities transported by rail and through Canadian ports. The association argued that this approach would help preserve supply chain continuity while maintaining the right to strike and reducing the need for government intervention.

WWH from employee groups

One union maintained that no broader changes to the framework are necessary, arguing that most challenges could be resolved if decision-makers engaged meaningfully at the bargaining table. However, others proposed strengthening existing protections, particularly the replacement worker ban, by extending it to cover workers across locations, subcontracting, and the use of emerging technologies such as AI that could replace workers, while shifting the burden of proof to employers to demonstrate compliance with the ban, as well as enhancing enforcement by the Labour Program.

Additional suggestions included allowing workers to respect picket lines where negotiated, simplifying strike notice requirements, and addressing practices-such as redirecting work or use of foreign labour-that may undermine collective bargaining rights.

Several unions also called for broader reforms to modernize the labour relations system, including simplifying certification processes, improving access to employee information, removing final offer votes, strengthening first agreement arbitration, and expanding just-cause protections. They emphasized the need to address delays at the CIRB by increasing resources and streamlining processes, particularly for unfair labour practices and maintenance of activities decisions.

Some advocated for clearer timelines, easier access to arbitration without demonstrating bad faith, and updated provisions to reflect evolving work arrangements such as telework, while recognizing that comprehensive reforms may be needed to better support effective collective bargaining.

WWH from Indigenous partners

The NIOs did not provide views on other potential changes to Part I of the Code.

3.2 Part II

3.2.1 Strengthening workplace health and safety protections

Occupational Health and Safety (OHS) protections create safer workplaces and support both workers and employers amid changing work environments.

The Government sought feedback on new measures to enhance OHS protections, including integrating psychological health and safety into regulations to proactively manage psychosocial risks, expanding the Labour Program's proactive outreach and inspections to prevent injuries, modernizing processes through automation and AI to deliver faster resolutions for workers, and improving access to specialized expertise to address complex and emerging hazards while supporting effective compliance and enforcement.

WWH from employer groups

In general, employers suggested minimal, targeted updates to the OHS framework, emphasizing that changes should be introduced in accordance with the fundamental principle of reasonable prevention and be proportionate to the employer's control.

Psychological health and safety

Employers emphasized that any new requirements must be practical and operationally feasible, particularly for smaller organizations, and supported by clear definitions, scope, and roles that align with the internal responsibility system. Many expressed concerns about the subjective nature of psychological health and safety standards and stressed the importance of providing employers with clear guidance and certainty regarding compliance obligations. Some stakeholders argued that the Code should continue to focus on protecting workers' physical and psychological health and safety, while addressing issues such as workload, organizational culture, and employee engagement through voluntary best practices rather than regulatory requirements. Others supported the formal recognition of psychological hazards under Part II of the Code, provided that any associated regulations include clear direction on prevention, privacy, information sharing, and the respective responsibilities of workplace parties.

Employers also identified practical challenges with the current workplace violence and harassment framework, including concerns that some complaints are unnecessarily escalated to formal investigations. Many called for greater flexibility for employers to assess and resolve complaints appropriately and recommended modernizing the framework to allow qualified internal human resources professionals to serve as investigators where appropriate. At the same time, some employers cautioned against introducing standalone psychological health and safety regulations without further analysis, citing potential implications for work refusal processes, regulatory complexity, and administrative burden. These stakeholders instead emphasized the need for efficient, practical tools that support timely decision-making and effective hazard resolution.

Modernizing processes using AI

One employer supported the use of artificial intelligence to assist with the early assessment and triage of hazard complaints and work refusals, while maintaining the Code's existing hazard assessment framework for addressing psychological health and safety and climate-related risks. Another employer proposed the creation of a centralized, technology-enabled OHS reporting portal to streamline compliance, reduce administrative burden, and support the collection and analysis of data to identify emerging workplace hazards and trends.

Improving access to expertise to address complex or emerging hazards

A few employers noted that existing regulations already address climate-related risks, while another argued that tailored and flexible regulations should be provided on climate-related hazards, including extreme weather, heat, cold, wildfire smoke, and ultraviolet exposure. A few employers raised concerns about the thermal stress regulations and advised these should be revisited before considering any further climate-related regulations.

WWH from employee groups

In general, unions made suggestions to broadly improve the framework under Part II, including the internal responsibility system that requires employees and employers to work jointly to address workplace hazards, as well as more specific changes.

Psychological health and safety

A few unions recommended incorporating psychological health and safety requirements directly into the Canada Occupational Health and Safety Regulations and/or introducing a definition of "psychosocial hazard" to ensure that mental well-being is addressed with the same level of importance as physical safety and that employers are required to identify and mitigate these risks. Another union recommended amending the Code to establish a harassment-free workplace as a minimum employment standard and creating a mechanism for meaningful joint resolution of workplace disagreements. This union also emphasized the importance of involving all workplace parties in developing and implementing solutions to incidents of harassment and violence.

One union further recommended formally recognizing the psychological impacts associated with AI-enabled management tools, including the effects of constant performance monitoring, surveillance, and algorithmic decision-making. It advocated for a comprehensive psychological health and safety framework that would require employers to identify and manage psychosocial hazards, take proactive measures to prevent harassment and violence, and address sources of psychological harm such as precarious employment, excessive workloads, and technology-enabled workplace monitoring.

Compliance approach

Unions highlighted the need for clearer and more consistent guidance on hazard prevention program requirements, noting variability in the application of internal complaint resolution processes across workplaces. Several recommended establishing clearer regulatory requirements and, in some cases, mandatory escalation mechanisms when issues remain unresolved. Unions also expressed concern that reliance on voluntary compliance, without adequate follow-up or oversight, can undermine effective enforcement. Some called for a significant increase in the number of enforcement officers and more proactive workplace inspections, as well as amendments that would allow workers to seek assistance directly from the Labour Program without first raising concerns with their employer.

One union emphasized that federal OHS requirements should better reflect the unique operational realities of port and marine workplaces rather than relying on frameworks designed for other sectors. It also identified jurisdictional overlap between the Labour Program and Transport Canada as a source of potential enforcement gaps and recommended clearer delineation of responsibilities to ensure that both authorities take action, rather than defer to one another, in areas of shared jurisdiction.

Improving access to expertise to address complex or emerging hazards

One union recommended that employers be required to develop, maintain, and periodically update emergency preparedness and evacuation plans to address OHS risks associated with climate change and extreme weather events.

A few unions called for updated federal standards governing occupational exposure limits, personal protective equipment requirements, and medical monitoring for workers exposed to complex or emerging hazards. They also advocated for the implementation of comprehensive fatigue risk management standards that go beyond prescriptive scheduling limits to address fatigue, irregular rest patterns, cumulative fatigue, and the unique demands of shift work and safety-sensitive occupations.

WWH from Indigenous partners

One NIO emphasized that any modernization of OHS regulations should respect the rights, autonomy, and distinct circumstances of First Nations. The organization also highlighted unique OHS challenges arising from infrastructure deficits in some communities, where multiple services and sectors may operate within shared facilities. For example, workplaces such as band administration offices and daycares may be co-located, creating overlapping workplace hazards and regulatory considerations that may not be adequately reflected in conventional OHS frameworks.

3.2.2 Working on labour mobility to harmonize training standards and regulations

Federal, provincial, and territorial governments are accelerating efforts to remove barriers created by OHS requirements, enhancing labour mobility across Canada.

The Government sought feedback on developing a harmonized, inter-jurisdictional training framework that aligns curricula across Canada. This would reduce variability, support effective compliance, and ultimately foster a safer and more mobile workforce for a stronger Canadian economy.

WWH from employer groups

Employer representatives broadly supported greater alignment between federal, provincial, and territorial OHS frameworks to promote consistency, facilitate labour mobility, and reduce administrative complexity. They generally supported harmonized training requirements, clearer regulatory expectations, and greater consistency in hazard prevention approaches across jurisdictions. At the same time, some cautioned against overly prescriptive or rigid requirements that may become outdated or fail to reflect the operational realities of different industries. Suggestions included using Canadian Standards Association as a foundation for OHS requirements where appropriate, avoiding one-size-fits-all training mandates, and developing a prioritized roadmap for harmonization focused on key areas such as electrical safety, traffic control, elevating devices, and working-at-heights requirements.

WWH from employee groups

Unions generally supported harmonization initiatives, provided they result in equal or stronger protections for workers rather than a lowering of existing standards. They emphasized that any harmonization efforts should be evidence-based, informed by subject-matter experts, and developed through meaningful consultation with unions and other stakeholders. Several unions noted that greater consistency in training, certification, and reporting requirements across jurisdictions could improve workforce mobility, support compliance, and contribute to the modernization OHS systems, including through the development of a national framework for safety training and reporting. In addition, some unions called for a review of protections for pregnant and nursing workers, highlighting approaches such as Quebec's preventive reassignment regime, which provides opportunities for workers to be reassigned to safer duties when workplace conditions may pose health or safety risks.

WWH from Indigenous partners

The NIOs did not provide views on labour mobility to harmonize training standards and regulations.

3.2.3 Other potential changes to Part II of the Canada Labour Code that could help better support fair and safe outcomes for workers

WWH from employer groups

Employers called for greater regulatory consistency and reduced complexity, particularly in sectors governed by overlapping regimes, and emphasized the need for improved coordination between federal bodies such as the Labour Program and Transport Canada. They recommended more flexible compliance approaches, including applying a "reasonably practicable" standard and allowing exemptions or alternative measures based on feasibility. Employers also highlighted the need for clearer guidance on fatigue, impairment, and post-incident responses-particularly in aviation-including defined thresholds, safeguards, and obligations, though views differed on introducing new impairment regulations. Some supported standardized definitions, mandatory workplace policies, and even supervised random fitness-for-duty testing for safety-sensitive roles, while others opposed additional regulatory burden. Overall, employers supported targeted improvements to provisions on harassment, violence prevention, fatigue, and substance use, while stressing the importance of maintaining flexibility and avoiding overly prescriptive requirements.

WWH from employee groups

Unions and labour organizations called for revisiting the definition of "danger" to better capture long-term and chronic health risks and updating OHS frameworks to address emerging workplace issues, including remote work, pandemic-related hazards, AI-enabled monitoring and surveillance, and the impacts of climate change. Some also suggested strengthening accountability mechanisms, including by exploring greater alignment between the Code and relevant provisions of the Criminal Code. Stakeholders recommended enhancements to guidance materials and compliance tools, including clearer timelines for employer action, improved distinctions between internal complaint resolution processes and the right to refuse dangerous work, and explicit recognition that inadequate staffing, insufficient training, or a lack of appropriate personal protective equipment should not be considered normal conditions of work. Additional proposals included strengthening hazard prevention programs to better address psychosocial risks, workload-related hazards, and other emerging issues, as well as developing joint audit and assessment tools to support collaboration between employers and workers.

Unions also emphasized the need for stronger enforcement and greater transparency. Recommendations included increasing the number of inspectors, strengthening penalties for non-compliance, expanding information sharing, and reducing reliance on compliance agreements or automated enforcement processes in certain circumstances. Several unions called for clearer roles and responsibilities for workplace health and safety committees, access to aggregate workplace incident and training data, and the establishment of defined timelines and escalation mechanisms for resolving health and safety concerns. Additional proposals focused on strengthening the Internal Responsibility System through measures such as joint risk assessments, enhanced fatigue management practices, and minimum safety standards. Some unions also advocated for broader worker protections, including improved reassignment options or income supports where hazardous conditions exist, stronger anti-reprisal measures, clarification of committee responsibilities with respect to non-employees in the workplace, joint investigations of workplace suicides where appropriate, and the establishment of ongoing consultation mechanisms for safety-critical sectors.

WWH from Indigenous partners

The NIOs did not provide views on other potential changes to Part II of the Code.

3.3 Part III

3.3.1 Strengthening protections against misclassification and wage theft

Misclassification and wage theft, particularly in the in the road transportation sector, can undermine workers' ability to earn a fair living and create an uneven playing field for employers that comply with labour standards. Misclassification occurs when workers who should be treated as employees are instead classified as independent contractors, limiting their access to labour protections, and statutory benefits. Wage theft refers to situations where workers do not receive the wages, benefits, or other compensation to which they are entitled. While workers may seek recourse through the Labour Program's complaints process, identifying violations and recovering unpaid wages can be difficult and time-consuming.

The Government sought stakeholder feedback on potential measures to prevent misclassification and wage theft, strengthen compliance with labour standards, and improve the ability of workers to access and recover their entitlements.

WWH from employer groups

An employer group in the trucking industry expressed that misclassification is prevalent in the road transportation sector and would like to see greater enforcement efforts, as well as synchronization of enforcement efforts with the provinces and territories.

"There is wage theft taking place, and it's widespread in our [trucking] industry. You know, the word, at least on the street, is that folks hardly ever see those wages actually come back to them. That it takes forever, months and months and months and months, even when orders are issued."

Additional perspectives raised by employer groups in the second round of consultations

Employers and employer organizations generally supported addressing wage theft and worker misclassification, while emphasizing that enforcement measures should be targeted, evidence-based, and proportionate to the nature of the non-compliance. They cautioned against broad regulatory approaches that may create unintended consequences or unnecessary administrative burdens for compliant employers and noted that solutions may need to reflect the circumstances of particular sectors.

One employer representative highlighted concerns about unpaid wages, illegal wage deductions, delayed wage payments, and employers evading accountability by dissolving operations before wages are recovered or penalties are imposed. The representative supported stronger enforcement measures and increased penalties to deter deliberate non-compliance and better protect workers.

One employer association argued that not all wage-related violations are intentional and recommended a risk-based enforcement approach that distinguishes between deliberate misconduct and inadvertent compliance errors. The association also emphasized the importance of education, simplified regulations, and opportunities to correct errors before sanctions are imposed.

WWH from employee groups

In general, union and labour representatives agreed that misclassification is widespread, especially in the road transportation sector and called for stronger enforcement, higher monetary penalties, and better coordination with the Canada Revenue Agency and the provinces to close loopholes. One union identified unpaid work and compensation practices in certain federally regulated industries as examples of wage theft and called for clearer definitions of compensable work and stronger legislative protections. One union noted the need for sufficient resources to proactively enforce the Code, rather than relying on self-audit compliance, noting that proactive inspections should be increased and targeted at sectors with significant misclassification and wage theft, including the airline industry, and not be focused solely on the road transportation sector.

Several unions and a worker advocacy organization emphasized the need for stronger enforcement measures, including greater use of deterrence tools such as Administrative Monetary Penalties (AMPs) and prosecutions, increased penalties for non-compliance, more timely complaint resolution, and improved mechanisms for recovering unpaid wages. They argued that limited government enforcement capacity and resources remain significant barriers to effective compliance and can undermine worker confidence in the complaints process. Stakeholders also raised concerns about the prevalence of worker misclassification, with some arguing that it should be treated as a deliberate form of non-compliance rather than an administrative misunderstanding. These participants called for enhanced enforcement efforts, including increased inspections, stronger penalties, and more proactive compliance activities. In addition, one union recommended establishing a formal service standard or timeline for the resolution of wage theft complaints.

"Under the current system, workers-not employers-bear most of the costs associated with wage theft. When employers withhold pay or provide partial pay, workers must still pay the rent and feed their families. In sectors such as road transport, substantial wages may be owed by the time a job ends. For example, a recent survey of federally regulated truck drivers found that 53 percent of drivers had unpaid wages over $10,000."

A union recommended introducing a statutory test that would require employers to demonstrate that a worker is properly classified as an independent contractor. It also proposed expanding the CIRB's authority to investigate non-standard work arrangements and include misclassified workers within appropriate bargaining units. Additional recommendations included placing the burden of proof on employers through clear classification criteria, adding a definition of compensable work to Part III of the Code, and strengthening protections against employer reprisals. The union also called for eliminating court fees for employees seeking to recover unpaid wages through Federal Court proceedings, adopting elements of British Columbia's freight transportation model, including an independent rate-setting commissioner, and enhancing enforcement through mandatory intergovernmental data-sharing and more proactive, sector-wide audits targeting misclassification practices, particularly in the road transportation sector.

Additional perspectives raised by employee groups in the second round of consultations

A few worker advocacy groups highlighted that workers in precarious forms of employment, including gig work, contracting arrangements, and other fissured workplace models, may be particularly vulnerable to wage theft and require additional protections. They also emphasized that the current complaints-based system often places the burden of enforcement on workers, who can face lengthy delays in obtaining remedies. One employee group emphasized that misclassification is a dominant source of wage theft in the construction industry.

Many participants called for changes to strengthen the recovery of unpaid wages and improve enforcement outcomes. These included extending the limitation period for filing wage complaints, increasing Labour Program resources to address complaint backlogs, and implementing stronger collection mechanisms to improve compliance with payment orders.

A few unions and worker advocacy groups recommended enhanced enforcement tools for employers who fail to comply with labour standards obligations, including stronger collection measures, broader liability for employers and intermediaries involved in employment relationships, and additional requirements for repeat offenders. One union also recommended licence suspensions, licence revocations, or temporary bans on access to temporary foreign workers for employers found to have violated labour laws.

Some participants supported significantly increased monetary consequences for wage theft, including interest on unpaid wages and enhanced damage awards designed to deter violations and compensate affected workers.

One worker advocacy group recommended introducing statutory definitions of "work time" and "regular rate of pay" to improve clarity and strengthen the protection of workers' entitlements under the Code.

WWH from Indigenous partners

One NIO expressed that they were opposed to any form of wage theft, which could have ripple effects in communities.

Additional perspectives raised by Indigenous Partners in the second round of consultations

One NIO raised concerns about potential unpaid work among flight attendants. Another NIO mentioned how wage theft can be mitigated through a clearer definition of work and working hours.

3.3.2 Additional Part III Measure Explored in the Second Round of Consultations

3.3.2.1 Medical leave with pay

Since December 2022, employees in the federally regulated private sector who complete an initial 30-day qualifying period of continuous employment with their employer are entitled to three days of medical leave with pay. Employees are then entitled to an additional day of medical leave with pay at the beginning of each month after completing one month of continuous employment with their employer, up to a maximum of 10 days per year. An employee may take this leave for the following reasons:

• personal illness or injury;
• organ or tissue donation from the employee;
• medical appointments for the employee during working hours; and,
• quarantine.

An employer may require a medical certificate from an employee who takes five or more consecutive days of medical leave. An employer may request a medical certificate no later than 15 days after the employee's return from leave.

The Code and Canada Labour Standards Regulations allow some flexibility when defining a year for the purposes of medical leave with pay entitlement. An employer may use the calendar year for this purpose or may choose to establish an alternate year period that it uses for calculating annual vacation entitlement.

The Government sought feedback on whether changes are needed to the medical leave with pay provisions, the administration of medical certification requirements, and whether the current framework is effectively meeting the needs of employees and employers.

WWH from Employer Groups

Many employers and employer representatives reported significant increases in medical leave with pay usage since the introduction of the 10-day entitlement and expressed concerns about misuse, citing patterns of absences around holidays, long weekends, sporting events, and other predictable periods. Some employers also reported instances where employees requested medical leave in advance or appeared to treat the entitlement as additional vacation leave.

Several employers and employer representatives advocated to significantly reduce the number of days of medical leave with pay an employee may be entitled to annually, exempt certain sectors from the application of the leave, or abolish the entitlement altogether. Many employers and employer associations argued that the current restrictions on requesting medical documentation limit their ability to address suspected misuse. A few employers advocated for the ability to request medical certificates after fewer than five consecutive days of absence or where there is a demonstrated pattern of potential abuse. Some also expressed concerns regarding the reliability of alternative attestation mechanisms.

"Most major employers already had protections in place to address this issue in the federal private sector, which has, in Canada, some of the best jobs in this country, some of the best pensions, some of the best benefits. So, in many respects, this solution was solving a problem that didn't exist."

A few employers and employer associations recommended allowing greater flexibility in how medical leave with pay entitlements are administered, including permitting employers and bargaining parties to determine the 12‑month entitlement period used for calculating leave accruals.

One employer association expressed concern that medical leave with pay can increase workloads for employees who remain at work, particularly in smaller workplaces where fewer employees are available to cover absences.

Another employer association argued that the current medical certification framework creates challenges in disputes regarding leave use because employers may be unable to obtain supporting medical documentation while still being expected to demonstrate misuse.

Many concerns were also raised about the interaction between the medical leave with pay and other leaves provisions or disability benefits, including the three paid days of personal leave, and employer-provided sick leave or short-term disability plans. Employers and employer representatives recommended limiting the ability to stack similar benefits by allowing existing employer benefit plans to apply instead of the medical leave with pay provision set in Part III of the Code.

WWH from Employee Groups

Nearly all unions, worker representatives, and advocacy groups supported maintaining the current medical leave with pay provisions, viewing them as an important public health, workplace safety, and worker protection measure. They emphasized that medical leave with pay allows employees to recover from illness without financial penalty and helps prevent the spread of illnesses in workplaces. Many also noted the particular importance of the entitlement for non-unionized and other vulnerable workers.

Many unions and worker representatives strongly opposed expanding employers' ability to require medical certificates, arguing that such requirements create barriers to accessing leave, place additional pressure on the health care system, and raise privacy concerns. A few participants cited concerns expressed by health-sector organizations regarding the administrative burden associated with medical notes. One union suggested that employers should be required to demonstrate reasonable grounds before requesting medical documentation and that a broader range of supporting documents should be accepted.

"I think the 10 days that are on the docket is exactly what federally regulated workers need. It's certainly what we see overseas, and so we don't need to tweak the system. And in fact, on the [requirement of] medical notes, 9 provinces have a prohibition because it's seen as a public health issue. If some employers, largely unionized, are having difficulties on how people are taking it, they've got to use their own grievance and arbitration process."

A few unions and worker advocacy organizations opposed employee attestation requirements, arguing that they could discourage workers from exercising their entitlement to medical leave with pay. However, a few unions supported signed attestations as a reasonable alternative to medical certificates, particularly given challenges workers may face accessing health care providers in a timely manner. One participant also expressed concern that employees may not be well positioned to defend the validity of an attestation if challenged by an employer.

A few unions and worker representatives rejected claims of widespread abuse of medical leave with pay, arguing that increased usage reflects improved access to paid leave rather than misuse. They suggested that concerns regarding attendance or abuse should be managed through existing performance management and labour relations processes rather than medical verification requirements. A few participants also suggested that allowing employees to carry forward unused leave could help address concerns regarding end-of-year usage patterns.

A few employee stakeholders viewed concerns regarding the stacking of benefits as relatively uncommon and suggested that such issues are best addressed through collective bargaining. A few unions and advocacy groups also recommended additional guidance and education to improve employer understanding and administration of the medical leave with pay provisions.

"This is about protecting workers, especially workers in precarious employment, and especially crucial in the federally regulated sector, where the spread of illnesses is a huge risk. And also, I want to say, during the COVID pandemic, workplaces were the biggest vectors of the spread of contagion, and that actually cost our economy millions and millions and millions of dollars."

One worker representative opposed giving employers unilateral flexibility to designate alternative 12-month periods for calculating medical leave with pay entitlements and suggested that any such changes should require union agreement. Another union argued that the current framework already provides sufficient flexibility through the use of calendar or vacation years.

WWH from Indigenous Partners

One NIO suggested that employers should cover the cost of medical notes when required. They indicated that limits should be placed on the amount of medical leave with pay employees can accrue and where accrued medical leave is eligible for payout. They also believed that employers should have the authority to require employees who are ill to leave the workplace.

Another NIO proposed that the cap on available medical leave with pay should be sufficient to bridge the gap to short or long-term disability.

3.3.3 Other potential changes to Part III of the Canada Labour Code that could help better support fair and safe outcomes for workers

Medical leave with pay was not a targeted focus in the first round of consultations. Nevertheless, participants provided significant feedback on the issue, leading the Government to include it as a discussion topic in the second round of consultations. Key perspectives from the first round have been summarized above. The following section focuses on the additional perspectives and recommendations raised during the first and second round of consultations.

WWH from employer and employee groups

An employer association and unions representing longshore workers in the Atlantic Ports requested an exemption to the 8-hour rest period rule.

WWH from employee groups

One union recommended reviewing hours-of-work scheduling rules to better reflect the operational and geographic realities of longshore work across Canada, while another called for stronger anti-retaliation protections for whistleblowers and improved enforcement of the right to disconnect. Another union recommended reviewing the definition of work to address concerns regarding unpaid work time in certain occupations, including flight attendants and similar roles.

WWH from Indigenous partners

The NIOs advocated for leave provisions, specifically for the purpose of incorporating leave for ceremonial practices (e.g., harvesting seasons) and a wider range of cultural activities.

3.4 Sustaining the Wage Earner Protection Program to ensure its integrity

The WEPP provides financial protection to employees whose employer becomes insolvent and ceases operating. Recent efforts to access WEPP payment in the context of corporate restructuring transactions, including through the use of reverse vesting orders (RVOs), have highlighted the need to clarify and reaffirm the Program's intended purpose.

A reverse vesting order (RVO) is a restructuring tool used in insolvency proceedings that allows unwanted assets and liabilities to be transferred out of a company, while the corporate entity itself is preserved and continues operating with its key contracts, permits, licences, and relationships intact.

The Government sought stakeholder feedback on potential measures to protect the integrity of the WEPP by ensuring that benefits are available in cases of genuine employer insolvency and business discontinuance, while preventing the Program from being used in restructuring situations where operations continue.

WWH from professional advocacy groups

A professional organization noted that workers experience job loss and income disruption in much the same way regardless of whether an employer enters bankruptcy, receivership, or a restructuring process. It highlighted the increasing use of RVOs in complex restructuring proceedings and noted that courts have developed established criteria to govern their use. The organization argued that the current WEPP framework may create inequities by excluding some workers affected by RVO transactions and recommended expanding eligibility to cover all employees whose employment is affected by an employer's insolvency.

The organization also proposed a number of administrative improvements, including streamlining application and payment processes, providing greater clarity regarding claims calculations, and ensuring appropriate protections for insolvency professionals to support timely administration of the Program. An arm's-length government body noted that RVOs are not explicitly set out in legislation but have evolved through case law, and observed that any legislative changes could have implications for how the WEPP interacts with restructuring proceedings that rely on these orders.

WWH from employee groups

Many unions urged the Government to ensure timely and reliable access to the WEPP regardless of the insolvency mechanism used, emphasizing that the Program serves as a critical safety net for workers facing job loss and unpaid wage claims. These stakeholders generally opposed measures that could restrict eligibility or delay payments and called for a review of the maximum WEPP payment to ensure they remain responsive to current economic conditions. Unions also proposed a range of enhancements to improve worker access and outcomes, including giving greater priority to severance claims, extending notice and application periods, and simplifying the application process, particularly through automatic enrolment mechanisms in large-scale insolvency events.

One union further recommended increasing the WEPP payment cap, strengthening the super-priority status of employee claims, broadening eligibility criteria, enhancing appeals and recourse mechanisms, and ensuring worker representation in insolvency proceedings. Additional proposals included imposing greater accountability on corporate directors, extending claim limitation periods, and establishing trust-based mechanisms to help ensure full compensation for affected workers. This union also called for limiting the use of RVOs to exceptional circumstances and subjecting their use to greater judicial scrutiny where worker interests may be affected.

A worker advocacy organization similarly recommended modernizing the WEPP to better reflect evolving employment and business structures. Its proposals included recognizing multi-employer and related-employer arrangements, improving access to WEPP payment for workers whose employers have ceased operations or cannot be located (e.g. walkaways), and extending eligibility to workers who have been misclassified as independent contractors.

WWH from Indigenous partners

One NIO agreed that the WEPP should be improved and strengthened.

3.5 Other potential changes to the Canada Labour Code that could help better support fair and safe outcomes for workers

3.5.1 Artificial Intelligence

The Industrial Inquiry Commission's report on West Coast ports highlighted the importance of supporting longshoring workers who may be affected by automation through access to training and skills development.

The Government sought stakeholder feedback on the impacts of artificial intelligence (AI) and automation on work, the adequacy of supports available to affected workers, and opportunities to strengthen access to training and workforce adjustment programs in the longshoring sector and across federally regulated industries more broadly.

WWH from employer groups

Some employers and employer organizations supported measures to help workers adapt to the impacts of automation and AI through enhanced training, reskilling, and workforce transition supports. Several advocated for a shared responsibility model, with employers, unions, and governments all contributing to the design, delivery, and funding of training initiatives, and some expressed support for a government-led training fund. These stakeholders emphasized the importance of ongoing collaboration and dialogue among workplace parties on technological change, both within and outside the collective bargaining process. At the same time, they acknowledged that technological advancement is inevitable and argued that public policy should support, rather than impede, innovation. Several employers also cautioned against overly prescriptive regulations that could limit flexibility, discourage responsible adoption of AI technologies, or hinder productivity and competitiveness.

WWH from employee groups

Many unions agreed that automation and AI have the potential to significantly disrupt workers and transform existing jobs, underscoring the need for robust training, retraining, and workforce adjustment supports. At the same time, they emphasized that technological change should not come at the expense of employment security and argued that support measures should complement, rather than replace, employers' existing obligations under collective agreements and Code to inform, consult, compensate, or otherwise support affected workers. Several unions called for legislative changes requiring employers to negotiate training and retraining measures when technological change affects jobs, while others advocated for broader government consultations on supports for workers impacted by automation and AI.

One union organization highlighted the scale of the workforce transition that may be required as AI adoption expands, emphasizing the importance of employer-funded retraining and upskilling opportunities, particularly in digital literacy and technology-related skills. It noted that workers may face barriers where collective agreements do not provide strong job security, retraining, or redeployment protections. The organization also stressed that retraining initiatives should support access to jobs of comparable quality and include measures such as income support, continuation of benefits, and pension protection during transition periods.

More broadly, most unions and labour organizations called for meaningful and ongoing consultation with unions regarding technological change, arguing that advance notice alone is insufficient. Several recommended legislated consultation requirements, mandatory joint labour-management committees on technological change and training, and the re-establishment of sectoral partnership forums to support collaborative planning and address workforce impacts across industries.

"We know that in the port sector, there is the possibility of implementing fully automated port systems that eliminate up to 90% of the jobs in a port complex. This is something that should be of national concern. With the elimination of those jobs goes the elimination of that income into communities that rely on the ports for their economic sustainability, for families and workers that rely on those jobs for economic sustainability. So, this is a big question."

Several unions recommended updating the Code to better address the implications of AI and automation in the workplace. Proposed changes included broadening definitions related to technological change, lowering eligibility thresholds for existing protections, and requiring employers to disclose and consult on the deployment of AI systems where they may affect workers' terms and conditions of employment. These stakeholders also advocated for principles such as worker access to information and data generated about them, limits on workplace surveillance and automated decision-making, and requirements for impact assessments and independent audits of AI systems to assess potential risks and biases.

Concerns were also raised about the use of AI-enabled technologies for worker monitoring, performance management, and discipline, particularly in the road transportation sector, where some unions reported growing reliance on surveillance technologies. These stakeholders called for stronger safeguards to protect worker privacy, transparency, and due process, as well as greater oversight of digital labour platforms and algorithmic management practices.

One union proposed a broader package of measures to support workers in adapting to technological change, including employer-provided training delivered on paid time, a risk-based regulatory framework for AI technologies, expanded access to digital skills development, public funding to support workforce adjustment, and training programs designed to meet the needs of diverse groups of workers. Additional recommendations included mandatory consultation with unions regarding technological change, prioritizing retraining and redeployment opportunities before layoffs, and explicitly incorporating AI-related risks into OHS requirements.

WWH from Indigenous partners

A few NIOs agreed that AI could be beneficial in reducing injuries and improving OHS in the workplace.

4. Written Submissions Across Both Rounds of Consultations

Written submissions were a critical and highly valued component of the consultation process. They enabled stakeholders to supplement roundtable discussions with detailed evidence, sector-specific analysis, and comprehensive policy recommendations. Collectively, the submissions provided an important source of insight and helped validate, deepen, and expand upon the themes that emerged during the roundtable consultations. Together, the written submissions and roundtable discussions provided a robust and complementary evidence base to inform the Government's consideration of potential policy and legislative reforms.

Across both rounds of consultations, the Labour Program received 319 written submissions from targeted and unsolicited stakeholders. In the first round, written submissions were due by May 25, 2026, and the Labour Program accepted 210 submissions through early June, including 110 employer associations, 53 labour organizations, 16 individual citizens, 2 parliamentarians or government officials, and 29 other organizations and associations. In the second round, written submissions were due by August 2, 2026, and the Labour Program accepted 109 submissions through August 5, 2026, including 63 employer associations, 21 labour organizations, 13 individual citizens, and 12 other organizations and associations.

The majority of unsolicited submissions came from employers and employer organizations whose operations are part of, or depend upon, Canada's supply chains. These submissions represented a broad range of sectors, including mining, tourism, agriculture, grain, potash, transportation and logistics, rail, aviation, ports and port infrastructure, shipping, ocean carriers, chemicals and fertilizers, and chambers of commerce. Most represented interests within the federally regulated private sector.

Consistent with the themes raised during the roundtable consultations, written submissions highlighted a fundamental tension between maintaining economic stability and supply chain continuity on the one hand, and protecting workers' rights and free collective bargaining on the other. In many cases, the submissions reinforced views expressed during the roundtables and provided additional evidence, examples, and policy proposals in support of those positions. At the same time, written submissions also identified areas of common ground. Stakeholders broadly agreed that the best and most durable outcomes are achieved through negotiated settlements at the bargaining table and generally supported measures that encourage earlier engagement, strengthen dispute resolution capacity, reduce unnecessary delays, and help parties resolve disputes before work stoppages occur.

However, significant differences emerged regarding the appropriate role of government when collective bargaining reaches an impasse. Labour organizations emphasized the importance of preserving the constitutional right to strike and limiting government intervention in collective bargaining. Employers, by contrast, stressed the need to prevent or mitigate labour disruptions that can have far-reaching impacts on workers, businesses, communities, critical supply chains, and the national economy.

While stakeholders expressed differing views on intervention mechanisms, there was a degree of convergence around the potential value of enhanced dispute resolution supports, particularly the use of special mediators to assist parties in reaching negotiated settlements before disputes escalate. Labour organizations generally supported the use of special mediators in defined circumstances as a means of facilitating voluntary agreements, while employers broadly supported the role as an additional tool to help resolve bargaining impasses and avoid work stoppages.

Greater divergence emerged with respect to section 107 and other forms of alternative dispute resolution that could influence or determine bargaining outcomes. Most employers supported retaining section 107 or establishing comparable mechanisms to address exceptional disputes with significant economic, national, or public impacts. Labour organizations generally opposed the use of section 107 because of concerns regarding its broad discretionary nature and its potential impact on collective bargaining rights and the constitutional right to strike. While some unions acknowledged that exceptional circumstances may warrant intervention, they emphasized that any such authority should be narrowly defined, subject to clear criteria and safeguards, and used only as a measure of last resort.

Most employer associations indicated that they had experienced direct or indirect impacts from labour disputes in the port, rail, and aviation sectors. Their submissions generally supported reforms aimed at reducing the frequency and duration of disruptions in these sectors, including longer bargaining timelines, enhanced mediation processes, the use of special mediators, and different methods of resolving disputes in cases where there could be significant economic consequences or affect the national interest. Many employers also supported retaining or clarifying the Minister's authority under section 107, with some recommending that economic impacts and supply chain disruptions be explicitly reflected in the factors considered when exercising that authority.

A recurring theme among employer submissions was the importance of maintaining continuity of operations in critical transportation and supply chain sectors during labour disputes. While requests for essential services designations was not a predominant theme of the consultations, several organizations proposed expanding maintenance-of-activities requirements or extending protections similar to those found in section 87.7 of the Code to additional commodities, transportation corridors, telecommunications infrastructure, and other critical supply chain functions. Employers also expressed support for mandatory special mediation processes, public reporting mechanisms, mediator-arbitrator models, and government-directed binding arbitration in disputes involving critical infrastructure or significant national economic impacts.

Labour organizations expressed strong concerns that several proposals advanced by employers could weaken collective bargaining rights or undermine the credibility of the right to strike. While unions generally supported mediation, expedited grievance arbitration, and, in certain circumstances, the use of special mediators, they also generally opposed extending bargaining timelines, introducing essential-services or maintenance-of-activities requirements, increasing government intervention, or expanding reliance on section 107.

Labour organizations consistently emphasized that dispute resolution mechanisms should support voluntary settlements rather than diminish bargaining leverage or be imposed unilaterally. Many also called for stronger protections against bad faith bargaining, additional resources for the FMCS and the CIRB, and clearer limits on government intervention in collective bargaining disputes.

Medical leave with pay emerged as one of the most prominent issues raised in written submissions, particularly during the second round of consultations. Stakeholders expressed sharply divergent views on the current regime. Labour organizations, worker representatives, and health-related organizations strongly supported maintaining the existing framework, emphasizing its public health benefits, the importance of preserving current restrictions on requests for medical certificates, and the need to avoid placing additional pressures on the health care system.

Employers generally supported the availability of medical leave with pay but argued that the regime would benefit from greater clarity and flexibility to address potential misuse. Their submissions focused on issues such as benefit stacking, equivalency with employer-sponsored benefit plans, medical certification requirements, administrative complexity, absenteeism, productivity impacts, and the potential for misuse. Employers and unions also differed regarding the interaction between statutory medical leave with pay and employer-provided benefits. Employers generally sought greater flexibility, while labour organizations viewed the current entitlement as an important minimum labour standard serving a distinct public policy purpose.

Beyond labour relations issues, written submissions identified several areas where stakeholder views were more closely aligned. Many participants supported stronger enforcement measures to address wage theft and worker misclassification, improvements to complaint and grievance resolution processes, greater institutional capacity for the FMCS and the CIRB, as well as increased enforcement capacity in the Labour Program, and enhanced supports for workers affected by automation and artificial intelligence.

Stakeholders also highlighted the importance of extending successor rights protections in cases of contract retendering and modernizing labour policy to reflect evolving workplace realities. Frequently raised themes included technological change, workforce training and adjustment supports, data rights, psychological health and safety, climate-related OHS risks, labour mobility, skills shortages, and changing patterns of work.

Overall, the written submissions made a substantial and important contribution to the consultation process. They largely confirmed, elaborated upon, and strengthened the themes that emerged during the roundtable consultations, while providing more detailed analysis, practical recommendations, and sector-specific expertise. Although the submissions reflected significant divisions on issues related to collective bargaining and government intervention, they also highlighted important areas of convergence, including strengthening worker protections, improving the effectiveness of labour relations institutions, supporting workforce adaptation to emerging challenges, and promoting productive, collaborative, and good faith labour relations. Together, the written submissions and roundtable discussions provided a comprehensive and robust evidence base to inform the Government's consideration of potential policy and legislative reforms.

5. Next Steps

We are grateful to the individuals, unions, employers, Indigenous partners and organizations who took the time to share their perspectives on strengthening Canada's collective bargaining framework and supports for workers. Through roundtable discussions and written submissions, participants provided valuable evidence, practical experience, and thoughtful recommendations on a broad range of labour and workplace issues. These contributions highlighted both the strengths of Canada's existing labour relations system and opportunities to make it more proactive, effective, resilient, and responsive.

The consultations reinforced that Canada's labour relations framework is working well in many respects, with the overwhelming majority of collective agreements reached through free collective bargaining. At the same time, participants identified opportunities to strengthen the framework's ability to address complex labour relations challenges, support workers through workplace transformation, OHS protections, and ensure federally regulated industries remain productive, competitive, and resilient. Stakeholders consistently emphasized the importance of maintaining strong worker protections, supporting constructive labour relations, and fostering stable workplaces that contribute to a strong and growing economy.

The consultations revealed meaningful areas of convergence. Stakeholders from across the labour relations community identified opportunities to strengthen dispute resolution supports, improve worker protections, modernize workplace health and safety frameworks, address wage theft and worker misclassification, support workforce adaptation to technological change, and enhance the effectiveness of federal labour relations institutions. These areas of agreement have helped identify practical opportunities where action may improve outcomes for workers, employers, and Canadians alike.

At the same time, participants expressed differing perspectives on several important issues, particularly regarding the role of government in collective bargaining disputes, the use of dispute resolution mechanisms in exceptional circumstances, and how best to balance the broader public and economic impacts of labour disruptions with the protection of collective bargaining rights. These differing views are an important outcome of the consultation process. They provide valuable insight into the complexities inherent in labour policy and help ensure that future policy development is balanced, evidence-based, and responsive to the diverse experiences and interests of workers, employers, Indigenous partners, and Canadians. By identifying both areas of consensus and areas of disagreement, the consultations have provided the Government with a stronger foundation for developing targeted and effective policy proposals that address emerging challenges while preserving the fundamental strengths of Canada's labour relations framework.

The input received through these consultations is providing an important foundation for future policy development. Together, the roundtable discussions and written submissions have created a comprehensive and robust evidence base that is informing the Government's consideration of potential policy proposals. This work will help shape measures aimed at supporting constructive bargaining, addressing emerging workplace challenges, strengthening federal labour relations institutions, protecting workers' rights, and ensuring that the Code continues to provide a modern, balanced, and effective framework for workers and employers.

As we move forward, the Government will continue working with workers, unions, employers, Indigenous partners, and other stakeholders to build on the strengths of Canada's labour relations system and address the challenges of the future. The perspectives shared through these consultations will help guide the next phase of this work as we continue building a stronger, more resilient, more competitive, and more prosperous Canada for all.

Annex A: Stakeholder Participants and Written Submissions

Round One Consultations April 17, 2026 - May 25, 2026

The following organizations participated in a virtual roundtable and/or provided a written submission as part of the consultation process.

List of Stakeholders Who Were Invited and Either Attended a Roundtable and/or Sent a Written Submission (58)

Employers and Employer Organizations (30):

1. Air Canada
2. Air Creebec
3. Air Inuit
4. Air Transat
5. British Columbia Maritime Employers Association (BCMEA)
6. Business Council of Canada (BCC)
7. Cameco Corporation
8. Canada Post
9. Canadian Bankers Association (CBA)
10. Canadian Chamber of Commerce
11. Canadian Federation of Agriculture (CFA)
12. Canadian Federation of Independent Business (CFIB)
13. Canadian National Railway (CN)
14. Canadian Pacific Kansas City Railway (CPKC)
15. Canadian Trucking Alliance (CTA)
16. Conseil du patronat du Québec (CPQ)
17. Fédération des chambres de commerce du Québec (FCCQ)
18. Federally Regulated Employers - Transportation and Communications (FETCO)
19. Halifax Employers Association
20. Jazz Aviation LP
21. Maritime Employers Association (MEA)
22. National Airline Council of Canada (NACC)
23. National Payroll Institute
24. NAV Canada
25. Orano Group
26. Railway Association of Canada (RAC)
27. TELUS
28. The Air Transport Association of Canada (ATAC)
29. WestJet
30. Western Canadian Shippers Coalition

Labour Organizations and Unions (23):

1. Air Line Pilots Association (ALPA)
2. Canadian Labour Congress (CLC)
3. Canadian Media Guild
4. Canadian Union of Postal Workers (CUPW)
5. Canadian Union of Public Employees (CUPE)
6. Confédération des syndicats nationaux (CSN)
7. CUPE - Air Canada Component
8. CUPE - Airline Division
9. Fédération des travailleurs et travailleuses du Québec (FTQ)
10. Grain Workers Union (GWU)
11. International Association of Fire Fighters (IAFF)
12. International Association of Machinist and Aerospace Workers
13. International Brotherhood of Electrical Workers (IBEW)
14. International Longshore and Warehouse Union (ILWU) - Canada
15. International Longshore Association (ILA)
16. Le syndicat des débardeurs (CUPE Local 375)
17. Longshoremen's Protective Union
18. Professional Institute of the Public Service of Canada (PIPSC)
19. Public Service Alliance of Canada (PSAC)
20. Teamsters Canada
21. Teamsters Canada Rail Conference
22. Unifor
23. United Food and Commercial Workers International Union (UFCW)

Indigenous Partners (3):

1. Assembly of First Nations (AFN)
2. Congress of Aboriginal Peoples
3. Les Femmes Michif Otipemisiwak

Wage Earner Protection Program (WEPP) Joint Liaison Committee Members (2):

1. Canadian Association of Insolvency and Restructuring Professionals (CAIRP)
2. Innovation, Science and Economic Development Canada (ISED)

List of Additional Stakeholders Who Sent a Written Submission (162)

Associations (28):

1. Alberta Forest Products Association
2. Association of Canadian Port Authorities
3. Assemblée de la francophonie de l'Ontario (AFO)
4. Calgary & District Labour Council
5. Canadian Association of Labour Lawyers (CALL)
6. Canadian Association of University Teachers (CAUT)
7. Canadian Manufacturers & Exporters (CME)
8. Canadian National Institute for the Blind (CNIB)
9. Centre for Israel and Jewish Affairs (CIJA)
10. Chamber of Shipping
11. Chemistry Industry Association of Canada (CIAC)
12. Christian Labour Association of Canada (CLAC)
13. FAIR Rail Coalition
14. Global Commodities Traders Inc.
15. Grain Farmers of Ontario
16. Greater Vancouver Board of Trade
17. Greater Vancouver Gateway Council
18. Institut Francophone pour l'Éducation, l'Équité et l'Innovation Sociale (IFEEIS)
19. Mining Association of British Columbia
20. Mosaic Forests
21. Moving Economies
22. Progressive Contractors Association of Canada (PCA)
23. Saskatchewan Association of Rural Municipalities (SARM)
24. Saskatchewan Mining Association
25. Tourism Industry Association of Alberta
26. Tourism Industry Association of British Columbia
27. Tourism Industry Association of Canada
28. Tourism Industry Association of Ontario

Employers and Employer Organizations (85):

1. Agricultural Producers Association of Saskatchewan (APAS)
2. Alberta Chambers of Commerce
3. Arjazon Seed Trading Ltd.
4. Armateurs du Saint-Laurent
5. Association des transporteurs de valeurs du Québec (ATVQ)
6. Association of Canadian Travel Agencies and Travel Advisors (ACTA)
7. Atlantic Chamber of Commerce
8. BC Chamber of Commerce
9. BC Marine Terminal Operators Association (BCMTOA)
10. Ben Line Agencies
11. BHP
12. Board of Trade in Newfoundland and Labrador
13. Bunge
14. Business Council of Alberta (BCA)
15. Business Council of British Columbia (BCBC)
16. Canadian Airports Council
17. Canadian Canola Growers Association (CCGA)
18. Canadian Construction Association (CCA)
19. Canadian Life and Health Insurance Association (CLHIA)
20. Canadian National Millers Association (CNMA)
21. Canadian Propane Association (CPA)
22. Canpotex
23. Cargill
24. CIFFA CORP
25. Coalition of Rail Shippers
26. Colley West Shipping LTD
27. Community Rail Advocacy Alliance (CRAA)
28. COSCO Shipping Lines
29. Council of Marine Carriers (COMC)
30. Dow Canada
31. DP World
32. Dry Cargo Chartering
33. Empire Grain Steve Doring LTD
34. Federated Co-operatives Limited (FCL)
35. Ferguson Bros of St Thomas Ltd.
36. Fertilizer Canada
37. Forest Products Association of Canada
38. G2 Ocean Shipping Canada
39. G3 Canada Limited
40. Glencore
41. Global Container Terminals
42. Greater Sudbury Airport
43. Halifax Port Authority
44. Hapag-Lloyd
45. Harmac Pacific
46. Hospitality Newfoundland and Labrador
47. Independent Contractors and Business Association
48. KSPC
49. La Chambre de commerce et d'industrie de Québec (CCIQ)
50. Maersk Canada
51. Montreal Port Authority
52. Mosaic Company
53. National Cattle Feeders' Association
54. Neptune Bulk Terminals
55. Nieuport Aviation
56. Ontario Chamber of Commerce
57. Pacific Coast Terminals
58. PAL Airlines
59. Pangea Logistics Inc.
60. Pembina
61. Port of Vancouver
62. Prince Rupert Grain Ltd.
63. Pulse Canada
64. Ray-Mont Logistics International Inc.
65. Retail Council of Canada
66. Richardson International Limited
67. Saskatchewan Chamber of Commerce
68. Saskatchewan Pulse Growers
69. SaskOilSeeds
70. Shipping Federation of Canada
71. SM Line Corporation
72. Southland Pulse Inc.
73. SSA Marine
74. Sultran Ltd
75. Sun Life Assurance Company of Canada
76. Surrey & White Rock Board of Trade
77. Swire Bulk Pte. Ltd.
78. Teck Resources Limited
79. Toronto Region Board of Trade
80. Trigon Pacific Terminals
81. Tsawwassen Shuttles Inc.
82. Western Canadian Short Line Railway Association
83. Western Grain Elevator Association
84. Windsor Port Authority
85. Winnipeg Chamber of Commerce

Labour Organizations and Unions (31):

1. Alliance of Canadian Cinema, Television and Radio Artists (ACTRA)
2. Aircraft Mechanics Fraternal Association (AMFA)
3. Association of Justice Counsel
4. BC Building Trades Council
5. Canada's Building Trades Unions (CBTU)
6. Canadian Air Traffic Control Association (CATCA)
7. Canadian Association of Professional Employees (CAPE)
8. Canadian Jewish Labour Committee
9. Directors Guild of Canada (DGC)
10. IAMAW Transportation District Lodge 140
11. International Longshore & Warehouse Union Canada (ILWU) local 502
12. International Union of Operating Engineers
13. Provincial Building and Construction Trades Council of Ontario (PBCTCO)
14. SPEA Local 7474
15. UBC Millwrights
16. UNIFOR 101
17. UNIFOR 112
18. UNIFOR 2000
19. UNIFOR 2002
20. UNIFOR 2289
21. UNIFOR 4211
22. UNIFOR 4212
23. UNIFOR 4285 and 4286
24. UNIFOR 5555
25. UNIFOR 6003
26. Unifor Council 4000
27. Unifor Local 401
28. Unifor Local 504
29. United Steelworkers local 1944
30. United Steelworkers Local 2004
31. Workers Education and Rights Collective

Provincial Government (1):

1. Government of Saskatchewan - Ministry of Highways

Member of Parliament (1):

1. Kyle Seeback, MP, Dufferin-Caledon, Ontario

Individual Citizens (16)

Round Two Consultations July 3, 2026 - August 2, 2026

The following organizations participated in a virtual roundtable and/or provided a written submission as part of the consultation process.

List of Stakeholders Who Were Invited and Either Attended a Roundtable and/or Sent a Written Submission (49)

Associations (3):

1. Air Transport Association of Canada (ATAC)
2. Business Council of Canada (BCC)
3. Cash-in-Transit Association of Canada

Employers and Employer Organizations (20):

1. Air Canada
2. Air Inuit
3. Air Transat
4. British Columbia Maritime Employers Association (BCMEA)
5. Canadian Bankers Association (CBA)
6. Canadian Chamber of Commerce
7. Canadian Federation of Independent Business (CFIB)
8. Canadian National Millers Association (CNMA)
9. Canadian National Railway (CN)
10. Canadian Pacific Kansas City (CPKC)
11. Canadian Trucking Alliance (CTA)
12. Federally Regulated Employers - Transportation and Communications (FETCO)
13. Halifax Employers Association
14. Maritime Employers Association (MEA)
15. National Airlines Council of Canada (NACC)
16. NAV Canada
17. Telus
18. Railway Association of Canada (RAC)
19. Western Canadian Shippers Coalition (WCSC)
20. Westjet

Labour Organizations and Unions (22):

1. Air Line Pilots Association (ALPA)
2. Aircraft Mechanics Fraternal Association (AMFA)
3. Canadian Labour Congress (CLC)
4. Canadain Media Guild
5. Canadian Union of Public Employees (CUPE)
6. CUPE Local 375
7. CUPE Local 4094
8. Canadian Union of Postal Workers (CUPW)
9. Confédération des syndicats nationaux (CSN)
10. Fédération des travailleurs et travailleuses du Québec (FTQ)
11. Grain Workers Union (GWU)
12. International Association of Fire Fighters (IAFF)
13. International Association of Machinist and Aerospace Workers (IAMAW)
14. International Brotherhood of Electrical Workers (IBEW)
15. International Longshore Association (ILA)
16. International Longshore and Warehouse Union (ILWU) - Canada
17. Parkdale Community Services
18. Public Service Alliance of Canada (PSAC)
19. Teamsters Canada
20. Teamsters Canada Rail Conference
21. Unifor
22. Workers' Action Centre

Indigenous Partners (4):

1. Assembly of First Nations (AFN)
2. Congress of Aboriginal Peoples
3. Les Femmes Michif Otipemisiwak
4. Native Women's Association of Canada (NWAC)

List of Additional Stakeholders Who Sent a Written Submission (76)

Associations (10):

1. Canadian Cancer Society
2. Canadian Manufacturers & Exporters
3. Canadian Telecommunications Association
4. Chemistry Industry Association of Canada (CIAC)
5. Council of Marine Carriers
6. Facilities, Operations, Maintenance/Management Association of Canada (FOMAC)
7. Freight Management Association of Canada
8. Greater Vancouver Gateway Council (GVGC)
9. National Payroll Institute
10. Ontario English Catholic Teachers' Association (OECTA)

Employers and Employer Organizations (46):

1. Armateurs du Saint-Laurent
2. Association of Canadian Travel Agencies and Travel Advisors (ACTA)
3. BC Chamber of Commerce
4. BC Marine Terminal Operators Association (BCMTOA)
5. Business Council of British Columbia (BCBC)
6. Ben Line Agencies
7. Canadian Canola Growers Association (CCGA)
8. Calgary Chamber of Commerce
9. Canadian Life and Health Insurance Association (CLHIA)
10. Canoptex
11. Cardinal Couriers
12. Chambre de commerce et d'industrie de Vaudreuil-Soulanges (CCIVS)
13. Chemtrade Logistics
14. CIFFA Corp.
15. Coalition of Railway Shippers (CRS)
16. Colley West Shipping Ltd.
17. Conseil du patronat du Québec (CPQ)
18. DP World Canada
19. Empire Grain Stevedoring Ltd.
20. Fédération des chambres de commerce du Québec (FCCQ)
21. Fertilizer Canada
22. G2 Ocean
23. GCT Global Container Terminals
24. Greater Vancouver Board of Trade
25. Groupe Desgagnés Inc.
26. Independent Contractors & Businesses Association (ICBA)
27. K+S Potash Canada GP (KSPC)
28. Maersk
29. MAIA Intelligence Inc.
30. Mining Association of BC (MABC)
31. National Maritime Group (NMG)
32. Neptune Terminals
33. Norden
34. Pacific Basin Shipping
35. Pacific Coast Terminals Co. Ltd.
36. Paterson Consulting Inc.
37. Prince Rupert Port Authority
38. Retail Council of Canada
39. Saskatchewan Mining Association
40. Shipping Federation of Canada
41. SSA Marine Canada
42. St. Lawrence Seaway Management Corporation
43. Surrey & White Rock Board of Trade (SWRBOT)
44. Sultran Ltd.
45. Tourism Industry Association of BC (TIABC)
46. The Mosaic Company

Labour Organizations and Unions (7):

1. Alberta Federation of Labour (AFL)
2. BC Building Trades Council (BCBTC)
3. Canada's Building Trades Unions
4. International Longshore and Warehouse Union (ILWU) Local 333
5. Seafarers' International Union of Canada (SIU)
6. United Food and Commercial Workers Union (UFCW)
7. United Steelworkers

Individual Citizens (13)