Welcome to the December issue of Blakes Competitive Edge, a monthly publication of the Blakes Competition, Antitrust & Foreign Investment group. Blakes Competitive Edge provides an overview of recent developments in Canadian competition and foreign investment law, including updates on enforcement activity by the Canadian Competition Bureau (Bureau), recent initiatives and key trends.
Key Highlights
- The Bureau has completed slightly more merger reviews year-to-date in 2025 (204) compared to the same period in 2024 (198), an increase compared to the same period in 2023 (182). The average length of reviews year-to-date in 2025 was 41 calendar days, slightly higher than the average review length of 40 days over the same period in 2024.
- The Bureau announces the resignation of Commissioner of Competition (Commissioner) Matthew Boswell.
- A new Minister of Canadian Identity and Culture is appointed.
- The Government of Canada announces a commitment by the United Arab Emirates to invest up to C$70-billion in Canada.
Competition Act
Merger Monitor
November 1 – November 30, 2025 Highlights
- 16 merger reviews announced; 18 merger reviews completed, with reviews taking 37 calendar days on average
- Primary industries of completed reviews: real estate and rental and leasing (28%); manufacturing (28%); mining, quarrying, and oil and gas extraction (11%)
- 8 transactions received an Advanced Ruling Certificate (44%); 9 transactions received a No Action Letter (50%); one transaction was resolved through other means
January – November 30, 2025 Highlights
- 211 merger reviews announced, 204 merger reviews completed, with reviews taking 41 calendar days on average
- Primary industries of completed reviews: real estate and rental and leasing (17%); manufacturing (15%); mining, quarrying, and oil and gas extraction (14%); finance and insurance (13%); wholesale trade (8%)
- 115 transactions received a No Action Letter (57%); 79 transactions received an Advance Ruling Certificate (39%); 7 transactions were resolved through other means; 2 transactions were resolved via consent agreement; and 1 transaction was abandoned by the merging parties
Merger Reviews Completed Year to Date Through November 30, 2025 by Primary Industry
Non-Enforcement Activity
Commissioner of Competition to Step Down on December 17
- On December 2, 2025, the Bureau released a statement announcing that Matthew Boswell, the Commissioner, would be stepping down on December 17, 2025. Mr. Boswell’s resignation comes ahead of the scheduled end of his term in February 2026. Jeanne Pratt, Senior Deputy Commissioner of the Bureau’s Mergers and Monopolistic Practices Branch, will become the acting Commissioner on December 18, 2025. As acting Commissioner, Ms. Pratt will exercise the powers and perform the duties of the Commissioner until a further announcement regarding the Commissioner position is made by the federal government. Such an announcement is likely to come in the new year.
Enforcement Activity
Bureau Advances Investigation into WELL Health
- On December 10, 2025, the Bureau announced that the Federal Court had granted its request for a section 11 order to compel information from WELL Health Technologies Corp. (WELL Health). WELL Health is a healthcare technology company that owns and operates medical clinics and provides electronic medical record software to clinics and practitioners. The order was granted in connection with the Bureau’s investigation into WELL Health’s acquisition of HEALWELL, including control over Orion Health. The investigation seeks to determine whether this consolidation is likely to result in a substantial lessening or prevention of competition for healthcare technology products and related services in Canada, including with respect to the acquisition’s impact on users, and whether the transaction raises barriers for competitors and new entrants.
Bureau Expands BWX Technologies–Kinectrics Merger Probe
- On November 19, 2025, the Bureau announced that it had obtained a fourth section 11 order in connection with its ongoing investigation of BWX Technologies’ acquisition of Kinectrics. The investigation concerns whether the transaction, which closed on May 20, 2025, is likely to result in a substantial lessening or prevention of competition in Canada’s nuclear medicine sector. Both BWX Technologies and Kinectrics provide products and services at various stages of the medical isotope value chain. The latest court order expands the investigation and requires Novartis, a firm also involved in the manufacture and sale of nuclear medicine products in Canada, to provide records and information relevant to the inquiry. For more information on the Bureau’s investigation of BWX Technologies’ acquisition of Kinectrics, see the Blakes Competitive Edge™: May 2025 Update.
Investment Canada Act
Foreign Investment Monitor
Non-Cultural Investments
- Information regarding Investment Canada Act decisions since August 2025 has not yet been published and will be addressed in a subsequent edition of Blakes Competitive Edge.
Non-Enforcement Activity
New Minister of Canadian Identity and Culture Appointed
- On December 1, 2025, Prime Minister Mark Carney announced the appointment of Marc Miller as Minister of Canadian Identity and Culture following the resignation of Steven Guilbeault from the position on November 27, 2025. Minister Miller will be responsible for assessing investments in “cultural businesses” that fall within the jurisdiction of the Investment Canada Act.
Federal Government Signs Investment Agreement and Secures Investment Commitment from United Arab Emirates
- On November 21, 2025, the Office of the Prime Minister announced that the federal government had entered into a foreign investment promotion and protection agreement (FIPA) with the United Arab Emirates. The FIPA was signed by Prime Minister Mark Carney during an official visit to Abu Dhabi. Once implemented, the FIPA will provide a framework for enhanced predictability and certainty concerning bilateral investments between Canada and the United Arab Emirates. As part of the announcement, the United Arab Emirates committed to investing up to C$70-billion in energy, artificial intelligence, logistics, mining and other priority national and strategic industries in Canada.
Blakes Notes
- Blakes continues to achieve recognition as one of Canada’s top law firms in The Legal 500 Canada 2026. The guide ranks 121 Blakes lawyers for excellence in their fields, including nine in the Competition, Antitrust & Foreign Investment group.
- The Blakes Competition, Antitrust & Foreign Investment group has once again been recognized as an Elite practice by Global Competition Review in the GCR 100 2026.
- Blakes has been recognized as one of the top firms globally for Foreign Investment Control work in the inaugural edition of Global Competition Review’s GCR 100: Foreign Investment Control.
- On November 20–21, 2025, two Blakes Partners, Julie Soloway and Fraser Malcolm, joined Mark Carney and a delegation of Canadians on a trade mission to Abu Dhabi, United Arab Emirates.
- Browse our thought-leadership insights from the Competition, Antitrust & Foreign Investment group to learn more.
Contact Us
If you have any questions, please do not hesitate to contact your usual Blakes contact or any member of the Blakes Competition, Antitrust & Foreign Investment group.