2024 Year in Review

Abstract

2024 marked a watershed moment in Canadian competition law, with some of the most significant legislative reform in decades now fully in force. The passage of both Bill C-56 and C-59 has reshaped the Competition Act, introducing a structural presumption for mergers, expanding private enforcement rights, and creating new provisions targeting environmental claims, among other things. These changes reflect a growing political and public appetite for stronger competition enforcement, resulting in increased activity from the Bureau, including its first merger remedy under the new structural presumption and a series of high-profile investigations and consent agreements.

The Bureau’s enforcement posture has become more assertive, and its policy agenda more ambitious. It has issued a flurry of draft guidelines and launched consultations on topics ranging from greenwashing to property controls, signaling a desire to shape the interpretation of the new regime. Yet, uncertainty remains—particularly around the scope of private access, the interpretation of “significant purpose” in civil collaborations, and the substantiation of environmental claims. As we move into 2025, stakeholders will need to navigate this changed landscape with care, balancing compliance with practicality to ensure that reform continues to serve both competitive markets and commercial realities.