Bill C-31, the Budget 2025 Implementation Act, No. 2, would amend many existing laws and create the Defence Investment Agency Act. Its stated goal is to implement measures from the November 4, 2025 budget; that goal is not a guaranteed result. The supplied material does not state whether the bill has passed, so these are proposed changes, not provisions that can be treated as in force.
It would create a federal Defence Investment Agency under a minister, and give that minister broad new powers over defence and national-security procurement, production and investment.
It would ban non-compete clauses for most federally regulated employees, with exceptions for certain business transfers and senior executives.
It would change air-travel complaint handling: the Minister of Transport would take responsibility, with options to use the Canadian Transportation Agency or approved third parties.
It would change pesticide reviews: the Minister would have to start a re-evaluation if an assessment gives reasonable grounds to believe a product’s health or environmental risks have increased significantly.
It would let the Governor in Council make national-interest orders affecting specified mineral rights on territorial lands in Nunavut. The Minister would decide whether certain affected rights holders receive compensation.
It would make many tax and financial-rule changes, including new crypto-asset reporting, new global minimum tax rules, broader CRA information-gathering powers, and an end to Canada Carbon Rebate payments for returns or adjustment requests filed after October 30, 2026.
Federal government and defence contractors: The Agency would assist the responsible minister. The minister would have exclusive authority to acquire defence supplies and services needed by federal departments, subject to exceptions. Competitive procurement would be the rule, but the minister could skip it for listed reasons, including urgency, national security, sensitive technology, or support for an important sector. The minister could also exclude a person from a competition on reasonable grounds of risk to national defence, national security or public safety.
Taxpayers and businesses: CRA may file a return for some eligible individuals who have not filed. This is a power, not a duty to file for everyone. Crypto-asset service providers would have to identify reportable users, collect and check tax-residency information, report transactions and keep records. A reportable person who fails to provide a requested tax identification number may face a $500 penalty, subject to stated exceptions.
Federal employees: Most employers covered by the Canada Labour Code could not agree to or impose a non-compete clause or a prescribed other employment restriction. Such clauses would be void, with a one-year transition for restrictions already in effect. Exceptions include certain business sellers who become employees and specified senior executives. Employers could not punish an employee for refusing a restriction.
Air passengers and carriers: Carriers would have to answer a written claim within 30 days. If a new third-party process is ordered, carriers would have to arrange for a designated person to resolve covered complaints. The Minister could set fees to recover complaint-handling costs.
Nunavut mineral rights holders: National-interest orders could cancel or restrict specified prospecting licences, claims, leases and transfers. Compensation would be considered for listed claim holders and lessees, but the Minister would decide whether to pay it and how much.
Other affected groups: The bill would raise the maximum amounts for some Tax Court informal-procedure appeals, change pesticide review timing, and permit non-discriminatory offers of certain deposit products. It does not itself promise that every eligible person will receive a federal benefit automatically.
No publicly available information on the bill’s overall estimated public cost is included in the supplied material.
The defence provisions would allow up to $1 billion in aggregate payments from the Consolidated Revenue Fund for specified purposes. Some recoveries would reduce that total; Parliament could change the limit through an appropriation Act.
The bill sets a $1 trillion ceiling on outstanding guaranteed principal for specified housing-related securities, plus later amounts authorized by Parliament. It sets a $500 billion limit for specified insured loans. These are limits, not estimates of spending.
The bill allows the Minister of Transport to establish complaint fees. No fee amount is given.
No cost estimate is supplied for staffing the Defence Investment Agency, tax changes, or other measures.
The supplied material does not include the amended Acts, so current-law rules and the exact size of changes to existing limits could not be verified.
Several major provisions need later orders or regulations to start or to set details, including defence procurement changes, the non-compete rules, and air-complaint changes. The bill does not give all start dates or all future rules.
It is unclear how much the new defence powers and Agency would cost in practice, and how the $1 billion payment limit would be used.
The bill does not set out a complete process for deciding when Nunavut orders are in the national interest or how compensation amounts would be calculated.
The bill’s CRA return-filing power has detailed eligibility tests, but the Minister may also set other conditions. The supplied text does not explain how the power would work in practice.
A possible argument for the defence changes is that one minister with broad authority could coordinate procurement, production, investment and stockpiling for defence and national security.
Competitive procurement would remain the default, while listed exceptions could allow faster or more suitable purchasing in urgent or sensitive cases.
The non-compete ban could give many federally regulated employees more freedom to take competing work after leaving a job.
The pesticide approach would require a re-evaluation when an assessment finds reasonable grounds of significantly increased risk, while allowing reviews to focus on the aspects of concern.
The defence minister could bypass competition for many listed reasons, and could exclude a person from a competition without giving reasons. That concentrates significant discretion in one minister.
The bill does not fully set the future procurement, employment-restriction or complaint rules; regulations and orders could shape how these changes affect people.
In Nunavut, the government could cancel or restrict specified rights, while compensation is limited to listed holders and left to ministerial determination.
A new tax penalty can apply when a person does not comply with information requirements, and the bill expands the CRA’s powers to demand information and documents. The consequences may be significant even though the bill includes review and exceptions.