Fortifying Ontario’s Economy: A vision for protecting Ontario, strengthening economic sovereignty, and securing global leadership in critical minerals
Purpose
The Ministry of Energy and Mines (MEM) is seeking feedback on a vision for updating Ontario’s Critical Minerals Strategy through a voluntary information notice on its vision paper
Proposal Number ERO 026-0427 (Ministry of Energy and Mines)
Submission Date June 15, 2026
Overview
The Ontario Chamber of Commerce (OCC) welcomes the opportunity to provide input on the province’s vision to renew its Critical Minerals Strategy Its vision represents a clear evolution toward a coordinated, whole-of-government, value-chain-based approach to critical minerals development, spanning from exploration to manufacturing.
As outlined in the OCC’s recent report, Mining 2030: Unearthing Ontario’s Potential, mining is essential to economic growth, national security, and the global energy transition. Enabling the mining sector’s role as a strategic pillar of Ontario’s economy requires decisive action to address persistent barriers, from regulatory reform to talent to timelines to northern development. Further clarity on the strategy’s implementation timelines, measurable outcomes, and investment mechanisms will be essential to ensure progress and accountability.
Capital Market & Exploration Opportunities
Ontario’s critical minerals sector is inherently capital-intensive, high-risk, and long-cycle, with projects often requiring more than 25 years from discovery to production. While Ontario is geologically advantaged, investment decisions are heavily shaped by fiscal risk due to large upfront capital requirements and a low exploration success rate, as well as external pressures, including commodity price volatility, global competition for capital, regulatory uncertainty, and limited access to patient capital – particularly in early-stage development.
As highlighted in the OCC’s Mining 2030 report, exploration incentives should be strengthened to better ensure projects have reliable access to capital and position Ontario as one of the most competitive fiscal regimes in Canada. Introducing a competitive exploration tax credit would bring the province in line with jurisdictions such as British Columbia and Quebec, which
currently offer direct, refundable tax credits to incentivize exploration and reduce early-stage project risk.
Alongside these tax changes, Ontario should also encourage greater participation from public pension funds and other institutional investors in the mining sector. These investors manage substantial pools of long-term capital and are well suited to invest in strategic assets that deliver sustained economic benefits. Increasing their involvement in domestic mining and critical mineral projects could strengthen supply chain security, drive economic growth, and enhance the province’s long-term competitiveness
The OCC agrees with Fortifying Ontario’s Economy on the role government must play in facilitating strategic capital coordination and investment de-risking. However, there is a need for clarity on how Ontario will operationalize this role, particularly in the context of intensifying global competition from jurisdictions offering substantial subsidies and industrial policy support (e.g., the United States and European Union) This could include clearly defined mechanisms such as contracts for difference, loan guarantees, anchor investments through public funds, or aligned tax incentives that directly reduce project risk and crowd in private capital.
Recommendations
To remain competitive, Ontario must evolve from a regulator to a co-investor and work with the federal government to expand investments when and where needed. This includes:
1. Strengthening exploration financing:
a. The federal government should expand flow-through share (FTS) eligibility for the Canadian Exploration Expense (CEE) by including the costs of technical studies.
b. To address challenges with declining junior exploration capital, Ontario should introduce an exploration tax credit that is stackable with the federal flow-through share rules to support more exploration activity and the development of new mines.
2. Expand risk-sharing financial tools: The Ontario and federal governments should explore financial tools, such as contracts for difference, to provide greater long-term price certainty and maximize capital leverage for some critical minerals identified in the province’s Critical Minerals Strategy.
Enabling Infrastructure
Infrastructure gaps are one of the largest constraints on critical minerals development, especially in Northern Ontario. These include roads and broader transportation assets, grid connectivity, and the social infrastructure (e.g., healthcare, childcare, and housing) required to support families and sustain long-term settlement in mining communities. Ontario must address these gaps through multi-use, dedicated investments in infrastructure and a long-term strategic view on economic development across Northern Ontario
Roads & Social Infrastructure
Reliable road infrastructure is critical to the success of Ontario’s mining sector, yet many northern highways require significant investment. The OCC supports the proposed approach to leading with roads, transmission, and coordinated regional planning to reduce project risks and improve access.
Additionally, Northern communities face persistent shortages with social infrastructure (e.g., housing, healthcare, childcare) and digital connectivity, relative to other parts of the province, which directly affect workforce attraction, retention, and long-term settlement. Housing supply is limited, aging, and costly to expand, while physician shortages and lack of childcare constrain families’ ability to relocate. These challenges are often more pronounced in First Nations communities, where land availability and lengthy Additions-to-Reserve (ATR) processes delay housing development.
Success could be measured using metrics and data on population growth and employee retention in mining regions; housing availability and quality; access to healthcare and childcare services; increased local and Indigenous employment participation; and broader economic activity and private investment enabled by infrastructure.
Fly-In-Fly-Out (FIFO) Programs
Although mining is a leading employer in Ontario’s north, many mining employees are recruited from outside the region to address a sustained shortage of skilled labour. FIFO programs have emerged as a critical part of the industry’s strategy, enabling companies from across the spectrum to leverage models that suit their unique needs and those of their employees For some more remote mines, they may be the only option. For others, these programs can be difficult to sustain. For northern communities, the programs can impact tax contributions and local economic spin-offs. Where possible, Ontario must assist mining companies in augmenting FIFO programs by attracting and retaining a local workforce. This can help build healthy and sustainable communities, contribute to the local tax base, and improve retention. Addressing workforce shortages, therefore, coordinated investment in the social and community infrastructure that makes relocation viable.
Recommendations
1. The Ontario government should continue to invest in key roads, including Highways 69 and 144, that serve northern communities and mines and connect them to markets across the province and beyond.
2. Ontario should build on existing northern economic development plans, such as the Growth Plan for Northern Ontario and the Northern Ontario Heritage Fund, by creating a bold, long-term strategic framework which integrates multi-use corridor planning. This could draw inspiration from Quebec’s Plan Nord. Any plan must integrate physical,
social, and community infrastructure, ensure coordinated investment, and match scale and ambition to the demands of mining-led growth in the North.
Workforce Constraints
Mining is a leading employer in Ontario, directly employing approximately 22,000 people, but the demand for employees is growing as the existing workforce ages and retirements increase. One of the biggest risks to Ontario’s mining sector is the shortage of skilled labour. The Ontario Mining Association (OMA) estimates the province will need 5,000 additional mining workers by 2030 to meet rising demand.
Industry assessments project Canada’s most in-demand mining roles include engineers, electricians, millwrights, technologists, data specialists, and geologists. These positions require long training pipelines and continuous upskilling. Without broad coordinated action to address this issue soon, labour demands will severely limit Ontario’s mining potential.
As the ministry works to build a mining-ready talent pipeline, it should invest in and scale innovative experiential learning programs like the “Greenstone Grind,” developed by the University of Toronto’s Lassonde Institute of Mining. This program provides students with hands-on exposure to mining and helps them envision careers in the sector. Expanding programs like this would reach more students across disciplines and help build the skilled workforce needed to unlock Ontario’s full mining potential.
Immigration is also a critical lever to address labour shortages in Ontario’s mining sector, helping to stabilize the workforce, support project development, and strengthen northern and rural communities. The federal Rural and Northern Immigration Pilot (RNIP) has been a notable success
Another integral labour pool for the sector is Indigenous peoples, who represented 12 per cent of Ontario’s mining workforce over 2023 and 2024. Their participation represents both a critical labour solution and a pathway to economic reconciliation, either through direct roles on mining projects and through procurement from Indigenous businesses, which has a strong local impact
Yet, Indigenous peoples still face many obstacles to gaining employment in the sector due to a lack of relevant education and training opportunities. Expanding Indigenous employment requires coordinated action by industry and government to strengthen training pathways, support Indigenous-owned businesses, and build long-term partnerships to ensure a steady pipeline of skilled workers and sustain community development.
Recommendations
1. Ensure the Ontario Immigrant Nominee Program supports northern labour market needs by expanding regional allocation streams. Building on Ontario government pilots such as REDI (Regional Economic Development through Immigration) and the Employer Job Offer (Northern Ontario Stream), the province should commit to a predictable and scaled pathway.
2. Ontario should build upon the successes of the Indigenous Economic Development Fund and support Indigenous businesses and communities in learning about the procurement supply chain RFP processes. Local mining, supply, and service companies should engage early with Indigenous businesses to share their long-term investment plans, specifically identifying opportunities to improve Indigenous participation in procurement.
3. Collaborate with mining companies to strengthen partnerships with Indigenous training institutions, apprenticeship programs, and northern colleges to ensure a sustained pipeline of skilled Indigenous workers in the mining sector.
Energy & Digital Infrastructure
Energy is one of the largest expenses for most Ontario mines, accounting for 15 to 30 per cent of total costs. As a result, maintaining stable and affordable access to energy, while integrating digital and advanced manufacturing systems, is fundamental to mining competitiveness.
While many mines have looked to electrify their operations, replacing equipment and retooling can be prohibitively expensive. Volatile, rising electricity prices will undermine the business case for electrifying the mine and discourage investment. As Ontario aspires to grow its mining economy, it must address the combination of energy supply scarcity, price volatility and rising costs, which the province’s current industrial frameworks are not designed to manage.
Overall, Ontario has abundant geological resources essential to the global energy transition and the broader industrial economy, along with a strong base of existing processing infrastructure, including two nickel smelters. Despite this, large volumes of mineral concentrates and intermediate products are still exported for processing in other regions, including countries such as China, which currently dominates many parts of the global critical minerals value chain.
To fully realize the economic potential of its resource base, Ontario should prioritize not only expanding mineral extraction but also strengthening domestic capabilities in processing, refining, manufacturing, recycling, and advanced technological applications. Enhancing inprovince processing capacity would help retain more economic value in Ontario, bolster supply chain resilience, and reduce dependence on foreign processing hubs. To achieve this, Ontario should continue fostering the economic and policy environment needed to attract investment in processing infrastructure and ensure that existing programs, such as the Ontario Critical Minerals Processing Fund, are effectively designed to support mineral processing initiatives.
Recommendations:
1. The Ontario government should consider all available options, including rate mitigation, to protect the province’s industrial foundation from the impacts of rising and more volatile electricity prices over the next decade.
2. The Ontario government should index the Northern Energy Advantage Program to the Consumer Price Index (CPI) and extend the program term beyond five years to give rate relief for mines and provide business certainty over the next decade.
Regulatory Reform
Government processes (e.g., environmental assessments, permits, approvals, and related consultations) are key contributors to prolonged timelines for opening a new mine. Project proponents must navigate long, complicated, and often duplicative regulatory processes, which are frequently cited as the most significant barrier to mining investment. PwC modelling suggests that bringing Ontario’s permitting timelines closer to leading jurisdictions could support an estimated $1-$2.2 billion in additional annual GDP.
Today, a single project can involve more than 80 different permits across its lifecycle, each with separate conditions, timelines, and consultation obligations. Environmental assessment processes add further complexity, especially in circumstances involving duplicative federal reviews. Additionally, inconsistent government guidance on Indigenous consultation and accommodation has led to significant logistical and financial complications for mining companies. At the same time, Indigenous communities are often inundated with consultation requests for the same project, with varied requests due to a fragmented process between the provincial and federal governments This can strain relationships with communities, leading to both consultation fatigue and time delay for project proponents
The transition to a “One Project, One Process” (1P1P) approach represents an important step towards simplifying and expediting regulatory processes for designated mines In time, Ontario’s regulatory system must reduce timelines for all projects operating in Ontario, including derisking new development at established mines and ensuring business continuity and environmental compliance.
Recommendations
As Ontario works to reform its regulatory regime, the following principles should guide implementation:
1. Ontario’s regulatory system should reduce permitting timelines for all mining companies operating in Ontario. As Ontario works to reform its regulatory system, the following principles should guide implementation:
a. One point of contact for applications;
b. A ‘concierge’ within government to help proponents navigate the process from end-to-end;
c. Consolidated permitting into one, side-wide permit with coordination between orders of government to reduce duplication;
d. Expanded capacity within government;
e. A unified digital platform to submit and track applications; and
f. Firm deadlines to reach decisions for both new projects and for permits and amendments impacting operating mines.
Value Chain Development
As geopolitical tensions rise, Ontario has a generational opportunity to position itself as the premier, reliable supplier of critical minerals for North America’s manufacturing base and defence markets. Ontario should take a proactive and strategic role in engaging international partners through mechanisms such as the G7 Critical Minerals Buyers Club by actively participating in coordinated international procurement and supply chain initiatives and supporting business-to-business matchmaking - particularly for midstream and downstream opportunities.
To diversify trade and investment, the federal government should work with provinces to adopt a coordinated global strategy that reduces barriers and improves competitiveness, including aligning with federal trade efforts to expand market access in like-minded jurisdictions.
9. Indigenous Partnerships
Meaningful Indigenous participation must be foundational to critical minerals development, with Indigenous communities positioned as rights-holders and co-developers in projects and infrastructure, equity partners in mining and corridor investments, and key participants in the workforce and supply chain. For mining companies, early engagement, consultation, and collaboration with Indigenous communities extend beyond a legal imperative or operational consideration; they can often improve environmental outcomes, business performance, and long-term community benefit and wealth
The strongest outcomes are achieved through layered models, where equity participation is paired with procurement, workforce development, and early engagement in project planning. For mining companies, these partnerships foster deeper trust, more transparent communication, and shared accountability. To achieve this, Ontario should establish clearer and more coordinated consultation processes, including a single authoritative framework; expand Indigenous access to capital through loan guarantees and equity financing tools; invest in training, education, and procurement opportunities; and align resource development with investments in housing, healthcare, and community infrastructure. A partnership-based approach will support economic reconciliation while reducing project risk, improving outcomes, and strengthening investor confidence.
The OCC is aligned with the province’s draft vision paper commitment to prioritizing early, meaningful, and equity-based partnerships that support Indigenous communities as owners, partners, and beneficiaries across the critical minerals value chain.
Recommendations
1. Ontario should ensure that mining proponents are provided with a single list for consultation with Indigenous communities. This would require alignment across legal branches of government, with authority vested in a single point of contact to make final determinations regarding affected communities and the adequacy of consultation.
Further, Ontario should ensure that it coordinates with the federal government to align requirements between levels of government.
2. Ontario should remove ambiguity around administrative and community building expenses by ensuring that both upfront and ongoing partnership costs are eligible for Mining Tax treatment.
3. Expand Indigenous Financing programs such as the Indigenous Opportunities Financing Program (IOFP) under the Building Ontario Fund, and strengthen complementary supports such as the Indigenous Participation Fund (IPF) to enhance community capacity, participation, and long-term equity involvement in mining and critical mineral projects.
Conclusion
The Ontario Chamber of Commerce supports the province’s vision to strengthen economic sovereignty and global leadership in critical minerals, and welcomes the shift toward a more coordinated, end-to-end approach to value chain development. Realizing this vision will depend on addressing persistent barriers, including infrastructure gaps, regulatory complexity, capital access, and workforce and community readiness, while ensuring meaningful Indigenous participation at every stage of development.
With clearer implementation pathways, stronger alignment with federal partners, and targeted investments in enabling infrastructure, capital tools, and partnership models, Ontario can unlock its full potential. If executed effectively, the strategy can position the province as a globally competitive, integrated critical minerals hub- driving long-term economic growth, advancing reconciliation, and strengthening resilient supply chains.