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On February 4, 2026, the federal government re‑introduced legislation to advance a more integrated and accessible health information ecosystem in Canada. Now tabled as Bill S‑5, the Connected Care for Canadians Act ("CCCA") is substantively the same as Bill C‑72, which the federal government first introduced on June 6, 2024. We provided commentary on this earlier bill, which did not move forward after Parliament was prorogued and the federal election was called. Because Bill S‑5 is nearly identical to its predecessor, our original analysis remains applicable. You can view our previous commentary here.
The CCCA aims to enable a more connected healthcare system in which patients can securely access their own health information and providers can share health information seamlessly when needed. Most of the obligations contemplated in the CCCA fall on service providers and relate to interoperability requirements and a prohibition on data blocking. Much of the substance of these requirements and enforcement powers is left to the yet-to-be released regulations.
Key Elements
Unchanged from the former Bill C-72, the core features of Bill S‑5 include:
- A Federal Framework for Health Information Interoperability: The CCCA sets out a national framework intended to support the safe, secure, and efficient exchange of electronic health information across systems and jurisdictions. The legislation aims to improve patient and provider access, enable innovation, reduce duplication, and provide more coordinated care to enhance health outcomes for patients.
- Provincial Application: In a similar way to how PIPEDA (Canada's private sector privacy legislation) is a federal law that only applies in certain provinces and the territories, the CCCA would only apply in a province or territory that does not have its own requirements that are "substantially similar" to, or exceed, those established under the CCCA.
- Obligations for Health Information Technology Vendors: Vendors that license, sell, or provide health information technology would be required to ensure their systems are "interoperable", meaning that they must be capable of secure, complete, and timely exchange of electronic health information. Vendors would also be prohibited from engaging in "data blocking" practices that prevent, discourage, or interfere with the access to, use, or the exchange of electronic health information.
- High‑Level Legislation with Key Details to Follow: As with Bill C‑72, the substance of the regulatory framework, including compliance verification, complaint processes, and potential administrative monetary penalties, will be set out in forthcoming regulations. The current text remains intentionally brief, with significant operational detail still to come. We will continue to monitor developments as Bill S‑5 moves through the legislative process and when regulations are released.
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