Summary#
Bill 35, the Captive Wildlife Protection Act, 2025, would create a new Ontario law and amend the Fish and Wildlife Conservation Act, 1997. Its stated goal is to protect captive wildlife by licensing zoos and setting rules for their operation; that goal is not a guaranteed result.
- The Minister must appoint a Director and a separate Registrar. A person could not establish, operate or maintain a zoo without a licence.
- Applicants would have to provide animal, staff, site and emergency information, pay a prescribed fee and show proof of liability insurance. The Registrar must issue a licence if the listed conditions are met, subject to the refusal grounds in the bill.
- Licence holders would be subject to annual inspections. Inspectors could order them to fix contraventions; the Registrar could propose to suspend, revoke or refuse to renew licences.
- The Minister may make rules on care standards, conservation requirements and zoo closures, among other matters. These rules are not set out in the bill.
- The bill also restricts acquiring, possessing, trading, breeding or using wild animals, subject to a zoo-licence exception and exceptions for species and activities set by regulation. Existing zoos could operate without a licence for one year after the law starts, subject to conditions the Minister imposes.
- People who already own certain wild animals outside a zoo could keep them until they die if they do not breed them or use them for entertainment. They would have to register the animals and accept annual inspections.
What it means for you#
- Zoo operators: You would need a licence and would have to meet future care standards, training rules and other requirements. A licence could have conditions and would not transfer to someone else. Existing zoos would have one year to operate without a licence after the Act starts.
- People who own wild animals outside zoos: The transition rule would let some current owners keep an animal for its lifetime, but only if they register it, do not breed it or use it for entertainment, and accept annual inspections and possible orders. The bill does not give this transition to future owners.
- Other people acquiring or using wild animals: The bill restricts these activities unless they are under a zoo licence or involve a species used for an activity allowed by regulation. The regulations would determine which species and activities qualify.
- The public: The Director must report annually to the Minister on zoos, animals, inspections, orders and identified public-health, public-safety or animal-welfare concerns. The bill does not say that these reports must be made public.
- Taxpayers: The bill would require annual inspections and create government roles, but does not state how many staff or resources they would need.
Money#
The bill requires fees and liability insurance for zoo licences, but their amounts and the public cost of administering the Act are not given.
- The Minister must appoint a Director and a Registrar; the bill gives no staffing or cost estimate.
- The Chief Animal Welfare Inspector must ensure annual inspections of licensed zoos. Registered owners covered by the transition rule would also be inspected annually.
- The Minister may set licence fees and insurance amounts by regulation. No amounts are set in the bill.
What is unclear#
- The care standards, training requirements, conservation requirements, fees, insurance amounts and other key rules depend on future regulations.
- The bill does not set application deadlines or a decision timeline. It also does not explain how “sufficient financial resources” or “public interest” would be assessed.
- The terms “entertainment” and “conservation” are defined, but the bill does not explain how they would be applied in particular cases. “Mobile zoo” appears in a refusal ground but is not defined in the supplied text.
- The bill allows a Registrar to suspend a licence immediately without first proposing the suspension if the Registrar considers it necessary in the public interest. A licensee may request a hearing within 30 days, but the bill does not describe any further appeal.
- The Fish and Wildlife Conservation Act, 1997 and the Provincial Animal Welfare Services Act, 2019 were not supplied, so their current rules and the full effect of the amendments and incorporated powers could not be verified.
Case for#
- The bill appears intended to make zoo operators meet licensing, animal-care and safety requirements before they operate.
- Annual inspections and orders to fix contraventions could provide a way to check compliance and respond to problems.
- The animal inventory and annual reporting requirements could give the Minister information about animals, inspections and outstanding concerns.
- The transition rules would allow existing zoos time to seek licences and let some current owners keep animals without requiring them to surrender them immediately.
Case against#
- Many central protections depend on future regulations, so the bill itself does not say what care standards or conservation requirements zoos must meet.
- The Registrar’s licensing decisions include broad tests such as public interest and sufficient financial resources. The bill does not explain how those tests would be applied.
- The Minister may impose conditions on existing zoos during the transition, and the Registrar may suspend a licence immediately in the public interest. These powers could have significant effects, while the process and criteria are not fully detailed.
- Inspections, licensing and reporting would require public resources, but the bill provides no cost estimate or staffing plan.