Canadian Competition Bureau Releases 2025-2026 Annual Plan: Signals More Aggressive Enforcement Ahead

In this post, authors Chris Hersh and Katelyn Leonard (Norton Rose Fulbright) examine the Canadian Competition Bureau’s 2025–26 annual plan, which sets forth enforcement and policy priorities amid ongoing shifts in trade, market dynamics, and technology. The Bureau continues to build on its Strategic Vision and respond to sweeping amendments to the Competition Act enacted since 2022. With Canada assuming the G7 presidency, the Bureau is also aiming to take a leading role in shaping international discourse on competition and enforcement policy, aligning many of its priorities with those of the newly elected federal government.

Among the most notable updates for 2025–26 is the Bureau’s newly intensified focus on several key sectors. In the housing sector, the Bureau has begun scrutinizing rental market transactions more rigorously, especially the consolidation of properties by commercial landlords. For the first time, enforcement in the artificial intelligence sector has been listed as a priority, both in terms of industry oversight and internal capacity building. Meanwhile, ongoing investigations in the food industry continue, targeting conduct and mergers that could affect consumer pricing. The Bureau is also sustaining its enforcement activities in areas such as greenwashing and drip pricing, evidenced by recent legal actions like the one taken against Canada’s Wonderland over undisclosed mandatory fees.

In addition to these enforcement priorities, the Bureau is working to deepen its involvement in emerging competition issues and policy development. It plans to examine algorithmic pricing through consultations and research, as well as maintain focus on consumer data, advocating for portability and greater consumer control. Anticipating the June 2025 expansion of private enforcement access under the Competition Act, the Bureau is preparing to support legal developments in this area, already seen in its intervention in an abuse of dominance case. It also remains committed to addressing regulatory and interprovincial trade barriers and intends to initiate a new market study, leveraging its expanded legal powers to compel data. Although the industry focus of the upcoming study has yet to be disclosed, recent work in the grocery and airline sectors suggests continued attention to markets affecting consumers directly…

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