Recent Legislative Developments Relating To Greenwashing And Environmental Claims In Canada

As we approach the end of 2025, there are some legislative developments of note in the greenwashing space.

Federal Bill C-15

On November 18, 2025, the federal government introduced Bill C-15 as part of its efforts to advance its “Climate Competitiveness Strategy” outlined in the 2025 Federal Budget. Bill C-15 amends the “anti-greenwashing” provisions originally set out in Bill C-59, enacted in June 2024.

In an effort to clarify the Competition Act's greenwashing rules, Bill C-15 eases some of the standards imposed by Bill C-59, particularly around substantiation requirements for business-related environmental claims and private enforcement in respect of those matters. The two key changes introduced by Bill C-15 are:

1. Businesses no longer need to use an “internationally recognized methodology” to substantiate environmental claims about their business activities. Business activity claims will only require “adequate and proper substantiation.”
2. Private parties can no longer seek leave from the Competition Tribunal to pursue claims under the business activity provision. Enforcement of business activity claims lies exclusively with the Competition Bureau.

Notably, the rules for product-related environmental claims remain unchanged, as these must still be substantiated by “adequate and proper testing” and third-parties may continue to bring claims for product greenwashing.

Under the new rules, only the Competition Bureau can challenge environmental claims about a business' activities. Bill C-15 requires complaints to go through the Competition Bureau, which would then decide whether to proceed. This change responds to concerns that third-party actions created litigation uncertainty and discouraged companies from sharing legitimate climate-related information.

According to its guidance in respect of Bill C-59, the Competition Bureau interprets "adequate and proper" as an intentionally flexible standard that accommodates the contextual impression being given to consumers. Courts have defined the phrase as meaning fit, suitable and appropriate for the circumstances. Whether substantiation meets this standard depends not only on the literal meaning of the environmental claim, but also on the general impression conveyed to consumers by its representations, including context, wording, imaging and layout. Given the guidance issued by the Competition Bureau on the Bill C-59 amendments, this change is unlikely to impact the ability of companies to make future “net zero” claims.

With business activity greenwashing claims now in the hands of the Competition Bureau, the guidance issued by the Competition Bureau on the Bill C-59 amendments should provide more reliable comfort to companies preparing their environmental business claims.

Alberta's Bill 12

In Alberta, Bill 12 has become law in early December 2025. Under this legislation, the Securities Act (Alberta) has been amended to allow regulations to be made respecting circumstances in which a person is not liable in any action or proceeding pursuant to common law, an enactment or otherwise with respect to any information disclosed or omitted to be disclosed in compliance with or intended compliance with the Securities Act (Alberta) or the regulations to the Securities Act (Alberta), including but not limited to climate-related disclosure. It seems likely that any regulations issued under this amendment will be more effective in shielding companies from regulatory proceedings than from civil claims.

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