MFIPPA Transition Timelines
As a reminder, we have advocated that the government extend the transition deadline for privacy-related changes under the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA) beyond January 1, 2027. In response to our request, we recently received a letter from Minister Crawford. While he recognized the challenges of meeting this deadline with respect to available municipal capacity and resource pressures, his message states that he remains committed to implementing the new requirements on January 1, 2027.
While we are disappointed that the timeline was not extended, we remain committed to assisting and supporting members with the transition. As such, we continue to operate a shared resource centre for municipal staff to access templates, procedures, reports, and other materials for guidance. As you develop your own policies and other resources within your organizations, we encourage you to send these to us to make available as part of our shared resource centre. Our goal is for this shared space to be a one-stop shop for staff to review materials, learn from peers, and adapt items as needed for their own internal organizational use.
The ministry has also released additional guidance to support this transition. Yesterday (October 13), municipal clerks and chief administrative officers should have received a memo from the ministry with PIA guidance and templates. In case you did not receive this information, we will be uploading these items to the shared resource centre—for details on how to access, please complete our intake form below.
Municipal Accountability Act Regulation Consultation Submission
As a follow-up to our August 26 advocacy update, we submitted formal feedback to the government as part of the Bill 9, Municipal Accountability Act regulatory consultation.
Our submission contains a list of recommendations divided into two sections:
1. Administrative and Operational Considerations—containing specific comments about timing, capacity, costs, as well as specific and nuanced operational recommendations for guidance and processes.
Recommendations include:
- The ministry to take the lead in supporting municipal partners by conducting training and paying for integrity commissioner training to avoid each municipality having to independently develop or procure training. This includes:
- Providing inserts that can be easily added into existing orientation training
- Specific training modules and/or programs developed by the Province to support consistent implementation
- Templates and guidance
- The removal of the unanimous voting threshold on declaring a seat vacant (removal threshold).
- Adding more definitions to clarify the regulations, revisiting the application of the Code.
- Reviewing the definition of local boards and how the Code provisions apply to the various types of bodies.
- Requesting the inclusion of specific provisions with respect to the use of corporate resources during election periods.
2. Health, Safety and Well-Being of Municipal Staff and Leaders—containing specific recommendations to improve the regulations within the existing legislative framework to better protect staff.
Recommendations include:
- The inclusion of compliance with corporate policies as part of the Code, including alignment with policies required under the Occupational Health and Safety Act and ensuring complementary investigation processes.
- Additional specificity with respect to harassment of staff, including additional statements describing harassment.
- Ensuring whistleblower protection and allowances for anonymity.
We have also requested guidance and clarity on how strong mayor/chair powers interact with provisions of the Code, given that some (such as commanding staff) may not apply to mayors and chairs (in certain instances). Clarity is also needed on whether strong chairs are bound by the Code of Conduct in the same way as other members and whether they could have their seat declared vacant if criteria and investigation warrant, given they are provincial appointees.
As indicated by the ministry, final regulations will be in place by November 15, 2026. We will monitor the release of these regulations and provide an update on what is included once available.
As always, AMCTO is here for you. Should you have any questions, concerns, comments, or suggestions for how we can support you in navigating these changes, please contact our policy and government relations team.