Changing the Script: Ontario Proposes to Regulate Preferred Provider Networks Between Insurers and Pharmacies

On November 6, 2025, the Ontario provincial government released its 2025 Fall Statement (Fall Statement), which proposes to regulate preferred provider networks (PPNs) in employer-sponsored drug plans.

Current PPN arrangements often take the form of exclusivity deals between insurers and pharmacies, whereby patients who rely on employer-sponsored drug plans are incentivized to only purchase their medications (partially reimbursed under their respective plan) from certain providers due to lower costs.

The government is proposing to introduce legislation that, if passed, would create a new “Any Willing Provider” framework, enabling any pharmacy that is willing to match a PPN’s financial terms to join it. This new framework would effectively eliminate the possibility for insurers and pharmacies to enter into exclusivity agreements (or “closed” PPNs). According to the Fall Statement, this framework would also be accompanied by a standardized, transparent process for patients to seek exemptions from PPNs where appropriate.

The government’s stated goal is to enable expanded consumer choice and competition in the pharmacy sector, while maintaining cost-effective access to medications. There are very few other details on the proposed legislation, and a draft Bill has yet to be released. The government has said that it will continue to collaborate closely with all stakeholders and regulators on the implementation of any proposed legislation.

In the past, the Ontario College of Pharmacists has publicly expressed its concerns regarding closed PPNs, alleging that they can have negative impacts on patient choice, continuity of care and timely access to pharmacy services. The Competition Bureau has also criticized certain business practices in the pharmacy sector involving PPNs and provided comments to the Ontario government on its concerns related to PPNs.

This announcement follows two consultations conducted by the Minister of Finance on PPNs over the past two years. If the proposed legislation materializes, Ontario would be the second province to have health legislation regarding closed PPNs. To date, only Quebec has such legislation.

For more information, please contact the authors or any other member of our Life Sciences or Health & Product Regulatory groups.