On September 4, 2025, the Canadian Competition Bureau (Bureau) announced its intention to conduct a market study into the state of competition for lending to small and medium-sized enterprises (SMEs) in Canada.
The Bureau has released a consultation paper outlining the market study’s purpose and scope and has invited interested parties to provide their views on the proposed market study’s terms of reference.
The Bureau’s market study will consider the following topics:
- Competitive dynamics in the SME financing sector
- Barriers to entry or expansion in providing financing to SMEs
- Barriers to switching lenders
The market study will focus on term loans and exclude other lending products such as trade credit, lines of credit, commercial mortgages and equity financing. The Bureau will publish the results of the market study and may make recommendations that, in the Bureau’s view, would improve competition.
This is the second market study launched since revisions to the Competition Act expanded the Bureau’s market study powers, including the ability to obtain court orders to compel the production of data and documents from market participants. For more information regarding the Bureau’s market study powers, see the Blakes Market Studies Toolkit.
Interested parties are invited to provide feedback to the Bureau’s consultation on the terms of reference for the market study by October 3, 2025. After considering the feedback, the Bureau will publish the final terms of reference, with the market study conducted on an anticipated timeline of:
- October/November 2025: Official study launch with publication of the final terms of reference
- January 2026: Deadline for contributions to the market study
- Fall 2025/Winter 2026: Stakeholder engagement and research
- Spring/Summer 2026: Analysis of potential solutions and recommendations
- Fall 2026: Publication of final report
For more information or if you are interested in providing feedback to this consultation, please contact any member of our Competition, Antitrust & Foreign Investment group.
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