On behalf of members, we have recently provided recommendations to the Province on two issues: Bill 100, Better Regional Government Act, 2026, and Bill 97, Plan to Protect Ontario (Budget Measures) Act, 2026, the latter specifically focused on changes to the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA).
Bill 100, Better Regional Government Act, 2026 Regulatory Submissions
To support the changes proposed through Bill 100, Better Regional Government Act, 2026, the Government posted two regulatory proposals for comment. We have responded to both proposals with a joint submission due to the intersecting considerations and impacts the proposed changes could have on administration, operations, and governance.
While we are appreciative of the clarity provided through these proposals, our submission offers further technical considerations that may require additional clarity, especially if powers are expanded to regional chairs. We remain concerned about the continued expansion of strong mayor and strong chair powers as they relate to organizational structure for employment matters. In our submission, we reiterate the call to remove these powers from the strong mayor framework and our opposition to the extension of these powers to regional chairs.
We also offer five overarching recommendations for consideration:
- Ensure language related to restricted acts is clear and avoids ambiguity; ensure language covers ’strong chairs’.
- Ensure the process for the removal of municipalities that reduce council composition to five members is clear moving forward.
- Remove the authority of strong mayors from administrative and employment matters, including the hiring and removal of municipal leaders and staff, and forgo extending these powers to regional chairs.
- Review and update Part VI.1 Special Powers and Duties of the Head of Council in collaboration with AMCTO to remove grey areas.
Consider technical modifications to support implementation in a two-tier structure (including weighted voting).
In case you missed it in last week’s Legislative Express, we also prepared a written submission to the Standing Committee on Heritage, Infrastructure and Cultural Policy’s review of Bill 100. As an Association, we will continue to push for legislative clarity regarding the implementation of strong mayor/chair powers and support our members through these transitions.
MFIPPA Recommendations
Bill 97, Plan to Protect Ontario (Budget Measures) Act, 2026, which made changes to MFIPPA, received Royal Assent on April 24, 2026, without an opportunity to provide formal feedback. As an Association whose membership is responsible for administering this legislation, we felt it was important to share the following recommendations:
- Ensure that municipalities have access to tools and resources required to implement changes.
- Amend implementation timelines to allow municipalities to achieve compliance while continuing to deliver essential services to the public, particularly as it relates to the requirement for privacy impact assessments.
- Provide legislative clarity on several provisions.
We will continue to emphasize the importance of a comprehensive review and update of the legislation to ensure it is fit for purpose.
As we work to determine the appropriate next steps to support our members through this transition, we invite you to send us your templates, policies, procedures, and other relevant resources related to:
- Privacy impact assessments
- Information management best practices
- Risk and breach management
- Job advertisement requirements for staffing
- Budget/business cases for more resources
Over the coming weeks, we will be reviewing materials to determine how we can best support you with implementing these new requirements. Thank you to those members who have already provided us with resources.
As always, we will continue to look for opportunities to advance our members’ interests and encourage you to get in touch with our policy and government relations team with any feedback, questions, or concerns.