Canada has introduced a wide-ranging economic reform bill that could significantly change the country’s rules for major infrastructure projects, transportation and supply chains, labour relations and, less visibly, digital trade.
Bill C-39, formally titled An Act respecting certain measures to strengthen the economy and carrying the short title Building Canada Strong Act, was introduced in the House of Commons on 21 September 2026 by the Minister of Transport and Leader of the Government in the House of Commons. It is a government bill in the first session of Canada’s 45th Parliament.
Although much of the public discussion around Bill C-39 has focused on major-project approvals and labour relations, the legislation also contains an important development for the digitalisation of international trade: it would enact a new Enabling Digital Trade Act, establishing Canada’s first federal legal framework for electronic trade documents.
Importantly, Bill C-39 is not yet law. As of 29 September 2026, it remains at second reading in the House of Commons. Committee consideration, report stage, third reading and consideration by the Senate have not yet taken place.
What is Bill C-39?
Bill C-39 is a broad economic reform package covering three principal areas: major-project approvals, transportation and supply chains, and the federally regulated workforce.
The Government of Canada presents the legislation as part of a wider effort to make investment and infrastructure development faster and more predictable, strengthen trade corridors and supply chains, and modernise federal labour rules.
The bill is divided into three main parts.
Part 1: Major projects and regulatory approvals
The first part focuses on the federal approval system for infrastructure, energy and other major projects.
Among other changes, Bill C-39 would amend the Impact Assessment Act to establish a framework intended to produce federal decisions on certain designated projects within one year after the project proponent has submitted the required information and studies.
It would also seek greater coordination between environmental assessments, federal permits and consultations with Indigenous groups. In some circumstances, federal authorisations could be incorporated into a single impact-assessment decision rather than being processed sequentially by different authorities.
The legislation would additionally amend the Building Canada Act, Canadian Energy Regulator Act, Canadian Navigable Waters Act, Canadian Environmental Protection Act, Species at Risk Act and Fisheries Act, among other legislation.
For certain energy infrastructure regulated by the Canadian Energy Regulator, the bill similarly aims to establish a one-year decision-making framework and improve coordination between assessments, consultations and federal authorisations.
The government has described these reforms as part of a broader attempt to create a “one window” approach for major federal project approvals.
Part 2: Transportation, supply chains and digital trade
The second part of Bill C-39 is particularly significant for transportation and international trade.
It would give the Minister of Transport authority to establish a transportation project office to coordinate federal approvals and consultations. The bill would also allow geographic areas to be designated as trade corridors and create a National Trade Corridors Council responsible for monitoring the movement of goods, analysing disruptions and advising the Minister.
Further reforms affect ports, railways, marine transportation, transportation security clearances and the St. Lawrence Seaway.
For example, the bill proposes changes to the Canada Marine Act intended to provide Canadian port authorities with additional organisational and commercial flexibility. It would also modify elements of the Canada Transportation Act, including information-sharing arrangements, railway rules and transportation-security powers.
Within this wider package is one of the bill’s most consequential digital provisions: Division 8 of Part 2 would enact the Enabling Digital Trade Act.
The Enabling Digital Trade Act
The proposed Enabling Digital Trade Act would establish rules allowing qualifying electronic trade documents to perform the same legal functions as their paper equivalents.
This matters because many traditional trade documents are more than containers of information. A bill of lading, for example, may give its lawful holder the right to claim goods or transfer rights relating to those goods.
Turning such a document into a PDF is not enough. An ordinary electronic file can be copied indefinitely, creating uncertainty over which copy represents the legally authoritative document and who is entitled to exercise the rights attached to it.
This is where the concept of an electronic transferable record becomes important. In the framework developed by the United Nations Commission on International Trade Law, or UNCITRAL, an electronic transferable record is a digital record capable of performing the legal functions traditionally performed by a transferable paper document or instrument. It can therefore represent not only information, but also rights that may be exercised or transferred electronically.
The Canadian proposal closely follows the principles of the UNCITRAL Model Law on Electronic Transferable Records (MLETR), adopted in 2017.
From physical possession to digital control
One of MLETR’s central concepts is control.
With a paper bill of lading, possession of the original document can determine who is legally entitled to exercise the rights associated with it. In an electronic environment, physical possession is impossible.
Control is the electronic equivalent of possession: the system must make it possible to establish which person has exclusive control of the authoritative electronic record and to transfer that control to another person.
According to Michael Geist’s analysis of Bill C-39, section 13 of the proposed Enabling Digital Trade Act provides that a requirement to possess a paper trade document can be satisfied electronically when a reliable method establishes both exclusive control of the electronic document and the identity of the person exercising that control. Transfer of possession would correspondingly be achieved through transfer of control.
The legislation also addresses writing, electronic signatures, endorsements, amendments and conversion between paper and electronic form. Use of electronic documents would remain voluntary rather than automatically replacing paper documents.
What is a “reliable method”?
Another central concept is the reliable method.
In simple terms, a reliable method is the technical and organisational process used to make an electronic trade document trustworthy enough to perform the legal functions of a unique paper original.
Such a system needs to do more than store a document. Depending on the applicable rules, it should be capable of distinguishing the authoritative record from copies, maintaining its integrity, establishing who controls it and ensuring that a transfer of control genuinely changes who can exercise the rights attached to it.
Bill C-39 would require reliable methods for several of these functions. Geist notes, however, that the Canadian bill does not itself reproduce the full range of reliability-assessment factors contained in the UNCITRAL model. Instead, section 21 would allow additional rules concerning reliability to be established by regulation.
That distinction may become important during implementation. Businesses and technology providers will need sufficient certainty that the platforms and processes they use satisfy the legal standard.
What could this mean in practice?
The most obvious application is the electronic bill of lading, or eBL.
A traditional bill of lading is widely used in maritime trade as evidence of receipt of goods, evidence of the contract of carriage and, in appropriate circumstances, a document controlling rights to the goods.
Under an effective electronic transferable-record regime, the legally authoritative bill of lading can exist digitally rather than requiring a paper original to be physically couriered between exporters, carriers, banks, buyers and other parties.
The same basic legal architecture can potentially support other transferable trade documents within the applicable jurisdiction.
Parliament’s official summary describes the Enabling Digital Trade Act as establishing rules for the use of electronic trade documents as the functional equivalents of paper trade documents relating to trade in goods.
The distinction is important: this is not merely about scanning paper documents or accepting electronic signatures. It is about allowing the digital record itself to become the legally authoritative instrument.
Canada is joining a wider international movement
Canada would not be the first jurisdiction to move in this direction.
According to UNCITRAL, legislation based on or influenced by MLETR has already been adopted in a growing number of jurisdictions, including Singapore, France and the United Kingdom.
The United Kingdom adopted the Electronic Trade Documents Act 2023, which entered into force in September 2023. The Act provides that an electronic trade document satisfying the statutory requirements can have the same legal effect as its paper equivalent and establishes criteria for the reliable system used to identify, protect and control the document.
France introduced its framework through Loi n° 2024-537 du 13 juin 2024 visant à accroître le financement des entreprises et l’attractivité de la France. Title II of the law expressly provides for the dematerialisation of transferable instruments. It recognises electronic transferable instruments and links their validity to requirements including uniqueness, exclusive control, identification of successive holders and preservation of integrity.
France subsequently adopted Décret n° 2025-811 du 12 août 2025, which specifies requirements for the “reliable method” used for electronic transferable instruments.
These examples illustrate an important next stage of digital trade policy: governments are moving beyond acceptance of electronic copies and signatures towards legal systems capable of supporting fully digital transferable instruments.
“Tell Us Once, Tell Us Digitally”
The digital trade provisions in Bill C-39 extend beyond trade documents themselves.
The Canadian government describes its broader policy as “Tell Us Once, Tell Us Digitally.”
The concept is relatively simple: a business should not have to provide the same trade information separately to several federal authorities. Instead, information should be submitted once in digital form and, where legally authorised, reused across government.
The government says the objective is to reduce duplicative reporting requirements and make the exchange and use of trade information faster and more efficient.
Bill C-39 therefore proposes to eliminate requirements to provide certain import or export information to the Government of Canada in physical form. It would also permit a federal minister, department or agency to disclose import- or export-related information where the receiving federal authority is legally permitted to collect that information.
Consultations preceding the bill showed considerable support for interoperable digital systems and reduced duplicate reporting, while participants also raised issues concerning privacy, security, data governance and the protection of confidential business information.
The information-sharing question
The proposed information-sharing powers are therefore one of the provisions likely to warrant close examination as the bill proceeds through Parliament.
Michael Geist argues that section 26 is broader than the administrative objective implied by the phrase “Tell Us Once.” In his analysis, the provision could permit import- or export-related information received by one federal authority to be disclosed to another authority permitted by law to collect it, without requiring the disclosure to serve the same purpose for which the information was originally provided. He also notes the absence of specific consent, notification and reporting requirements in that provision.
Geist further points to the interaction between the proposed disclosure provision and confidentiality provisions contained in several existing federal statutes, as well as the absence of a dedicated review clause or oversight mechanism in the Enabling Digital Trade Act.
These are analytical concerns raised about the bill, rather than conclusions contained in the government’s official description of the legislation.
The government frames the same measures primarily as a way to reduce duplication and enable secure reuse of information already submitted by businesses.
The distinction between those perspectives is important. The policy objective of avoiding repetitive reporting is relatively straightforward; the legislative question is how broadly information-sharing powers should be drawn in order to achieve it and what safeguards should accompany them.
The federal–provincial limitation
Another issue is Canada’s federal structure.
The proposed Enabling Digital Trade Act applies where the relevant legal requirement falls within federal jurisdiction. That makes it potentially important for areas such as navigation and shipping and certain federally governed commercial instruments.
However, aspects of property law, warehouse receipts, documents of title and the legal consequences of transferring goods can fall within provincial jurisdiction.
Geist therefore argues that federal legislation alone may not create a completely uniform Canadian framework for electronic transferable records.
This differs from jurisdictions such as the United Kingdom, where the Electronic Trade Documents Act 2023 can provide a more unified national framework for the covered documents.
For businesses operating across Canada, federal legislation may consequently be only one part of the legal transition towards fully paperless transferable trade documentation.
Part 3: Labour relations and worker protections
The third main part of Bill C-39 deals with federally regulated workplaces.
It would amend the Canada Labour Code to introduce new requirements and timelines for collective bargaining, provide additional mechanisms concerning first collective agreements and expand mediation and dispute-resolution tools.
The bill would also modify successor-rights rules in certain contracting situations and provide additional powers to the Canada Industrial Relations Board and the Minister of Labour.
Other provisions concern wage enforcement and amendments to the Wage Earner Protection Program Act.
The government says these measures are intended to modernise federal labour relations while strengthening protections for workers in federally regulated industries.
Where is Bill C-39 in the legislative process?
As of 29 September 2026, Bill C-39 remains relatively early in the Canadian legislative process.
The bill received first reading on 21 September 2026. Second-reading debate took place on 23, 24 and 25 September, and Parliament currently lists the bill as at second reading in the House of Commons.
It has not yet reached committee consideration, report stage or third reading. No recorded House of Commons votes on the bill are listed, and it has not yet reached the Senate.
If it proceeds through the normal legislative process, the principal remaining stages are completion of second reading, detailed committee examination, report stage and third reading in the House of Commons, followed by consideration in the Senate and Royal Assent.
The committee stage could be particularly important for the Enabling Digital Trade Act because this is where Parliament may examine detailed questions such as reliability standards, federal–provincial coordination and the scope of information-sharing powers.
The text should therefore still be treated as proposed legislation that may be amended, rather than as the final Canadian legal framework.
Why Bill C-39 matters for digital trade
The importance of Bill C-39 lies in a subtle but fundamental legal shift.
Digital trade documentation has existed for years, but digitalising the appearance of a document is different from digitalising its legal function.
A scanned bill of lading is still essentially a copy of a document. An electronic transferable record operating under an MLETR-style framework can instead become the authoritative legal instrument itself.
That makes it possible to transfer control rather than physically courier an original document.
For shipping companies, freight forwarders, exporters, importers, banks and trade-finance platforms, this can support faster document transfers, greater automation and closer integration between transport, customs and financial systems.
But legal recognition is only one part of the transition. Systems also need interoperability, technical reliability, information security and cross-border recognition if electronic trade documents are to move smoothly between different organisations and jurisdictions.
Conclusion: three issues to watch
Bill C-39 is much broader than a digital trade bill. It is a major economic reform package covering infrastructure approvals, environmental and energy regulation, transportation, ports, supply chains and federal labour relations.
The proposed Enabling Digital Trade Act nevertheless deserves attention in its own right because it could establish an important part of the legal infrastructure for paperless trade in Canada.
The main policy impact would be to integrate digital trade more directly into Canada’s broader supply-chain and trade-facilitation strategy. The combination of electronic trade documents and the “Tell Us Once, Tell Us Digitally” principle could reduce reliance on paper and duplicate government reporting. At the same time, the division of authority between federal and provincial governments means that Bill C-39 alone is unlikely to produce a completely harmonised Canadian system.
The main technical and legal impact would be the transition from paper possession to electronic control. Qualifying digital documents could themselves perform the legal functions of transferable paper originals, creating a stronger foundation for electronic bills of lading and other digital trade instruments. The practical significance will depend heavily on how the concept of a “reliable method” is ultimately defined and implemented.
The main open questions concern implementation and governance. Parliament and regulators will still need to address the reliability criteria applied to digital systems, coordination with provincial law, interoperability with international platforms and foreign legal regimes, and the safeguards surrounding government sharing of trade data.
Canada is therefore not simply proposing to replace paper with electronic files. Bill C-39 points towards a deeper change: a legal environment in which trade documents, the rights attached to them and the transfer of those rights can operate digitally from the outset.
Whether that framework becomes sufficiently predictable, interoperable and trusted will depend on the details that emerge as Bill C-39 proceeds through Parliament and, if enacted, into regulation.
Summary by DigitalTrade4.EU