Bill C-39: What Indigenous Communities Need to Know

The federal government has introduced the most significant overhaul of Canada's project approval system in a generation. Here is what it means for your community, your rights, and your future.

Introduced on September 21, 2026, Bill C-39, formally titled the Building Canada Strong Act, changes how major infrastructure, energy, and resource projects are reviewed and approved across Canada. The legislation affects environmental assessment, Indigenous consultation, and the pace at which communities must respond.

What is Bill C-39?

Bill C-39 is the federal government's sweeping reform of how major projects are reviewed and approved in Canada. While it is presented as a measure to reduce duplication, attract investment, and accelerate growth, it also changes the processes through which Indigenous communities exercise their rights and participate in consultations.

Understanding what this legislation does, and what it means for your community, is essential.

Why this matters now

The communities that prepare early will be better positioned to protect their rights, negotiate meaningful agreements, and shape outcomes on their territories. Waiting until a project is already in motion will leave very little room to catch up.

One-Year Federal Approval Timeline

Bill C-39 introduces a strict one-year maximum timeline for federal project review and approval decisions. Once a complete application is submitted, the federal government must issue decisions within that period, compressing the time communities have to prepare, commission studies, and engage.

One Project, One Decision

The legislation replaces multiple federal reviews with a streamlined process led by a single expert assessor. A single decision document is issued on behalf of relevant departments, which reduces duplication but also concentrates decision-making and narrows the points where communities can engage.

The Crown Consultation Hub

Bill C-39 creates a new Crown Consultation Hub to coordinate federal consultation with Indigenous Peoples. The stated goal is coordination, but consultation will also be faster and more centralized, so communities must be prepared to engage quickly and strategically.

What Bill C-39 Does Not Change

  • Canada's constitutional Duty to Consult remains intact.
  • Modern treaty obligations are preserved.
  • Environmental protection standards are maintained.

Preservation on paper does not guarantee meaningful implementation under a compressed process, which is why informed support matters.

What This Means for Your Community

The window to prepare is shorter than ever, and your leverage is greatest before approval. Communities that build capacity now will be better positioned to respond on their own terms rather than under pressure from an accelerated federal process.

The Window to Prepare Is Shorter Than Ever

Communities that once had years to build capacity, commission Traditional Land Use studies, and develop positions may now have far less time. Preparation has to happen before a project enters the pipeline.

Your Leverage Is Greatest Before Approval

Once the one-year clock starts, proponents will be under pressure and communities without a clear position, assessment, or advisor will be negotiating from a disadvantage.

Consultation Does Not Equal Consent

Bill C-39 preserves the Duty to Consult, but it does not create a right of veto. Communities must be organized and strategic to ensure concerns are genuinely heard and addressed.

Environmental Vigilance Remains Critical

Even where standards are preserved, compressed timelines and centralized decision-making raise real concerns about the depth of review in practice. Indigenous communities remain essential stewards of environmental integrity.

How Ugray Consulting Can Help

As a 100% First Nation-owned firm with government expertise in assessing and fulfilling the duty to consult and accommodate, industry experience in successful infrastructure megaproject planning and permitting, community capacity building, and lived Indigenous experience, we provide practical support tailored to the realities Bill C-39 creates.

Bill C-39 Community Briefings

Plain-language briefings for band councils and Indigenous organizations explaining what the legislation means for your community and territory.

Regulatory Readiness Assessments

We evaluate current preparedness and identify gaps before projects arrive so your community can respond from a position of strength.

Crown Consultation Hub Navigation

We help you engage effectively with the new centralized consultation process and make sure your rights are exercised fully within compressed timelines.

Traditional Land Use and Knowledge Documentation

We support the studies and evidentiary record your community may need before the clock starts.

Strategic Engagement Planning

We develop bespoke engagement strategies tailored to your vision, your timeline, and the specific projects affecting your territory.

IBA Negotiation Support

We help position your community to negotiate meaningful Impact Benefit Agreements before project approvals create momentum that is difficult to reverse.

Frequently Asked Questions

Does Bill C-39 take away our right to be consulted?

No. The Duty to Consult remains in place, but the process is being restructured and compressed, which makes preparation more important than ever.

Does the one-year timeline include Indigenous consultation?

Yes. Consultation happens within the one-year federal review timeline, alongside environmental assessment and permitting decisions.

What is the Crown Consultation Hub?

It is a new federal body created to coordinate consultation across departments and agencies. It is meant to reduce duplication, but it also makes the process more centralized.

Is Bill C-39 already in effect?

Bill C-39 was introduced on September 21, 2026, and is currently at second reading. Communities should prepare now rather than waiting for royal assent.

How do we know if a project falls under Bill C-39?

Projects subject to federal impact assessment, or regulated by the Canada Energy Regulator or Canadian Nuclear Safety Commission, will fall under the new framework. Contact us if you want help assessing a specific project.

Take the Next Step

Bill C-39 is a present reality that will shape how projects are approved on and near your territory for years to come. The communities that are best prepared will be best positioned to protect their rights and secure meaningful agreements.

Ugray Consulting Limited is here to walk alongside you, each step of the way.