Cost Recovery Advisory Group – 2026 Meeting Minutes

March 31, 2026

Hybrid meeting

Meeting agenda

• Introductions and opening remarks
• Adoption of the agenda and approval of the previous meeting minutes
• Review of the last year
• Operational management presentation
  • Update on Regulatory Activity Plans
• Financial management presentation
  • CNSC financial overview
  • Expenditure oversight and dispute resolution mechanism
• Other business
  • Updated CRAG Terms of Reference
  • CRAG member terms and renewals
• Concluding comments and next meeting

Meeting minutes

Industry participants

CNSC participants

1:00 p.m. – Meeting begins

Introductions and opening remarks

Julia Cropley, Cost Recovery Advisory Group (CRAG) Chair, opened the meeting and welcomed participants. She acknowledged that she was speaking from Ottawa, on the unceded and traditional territory of the Anishinaabeg, and recognized that participants were joining from Indigenous territories across Canada.

Julia welcomed 3 new representatives: Kent England of Cameco Corporation representing uranium processing facilities and uranium mines; Ben Bizzarri of Enzarri Consulting Services, representing industrial radiography for Western Canada in the nuclear substances and prescribed equipment category; and Ryan Leier from Transmountain Inc., representing fixed gauges in the nuclear substances and prescribed equipment category.

Adoption of the agenda and approval of the previous meeting minutes

Julia noted that the minutes of the last CRAG meeting, held on March 27, 2025, had been distributed to all CRAG members in a formal review period in April 2025. They have since been posted and are available on the Canadian Nuclear Safety Commission (CNSC) website. It was agreed that the minutes would be considered final.

The agenda for the current meeting was adopted as presented.

Review of the past year

In her review of the past year, Julia shared several notable developments for the CNSC, including:

• The CNSC’s refreshed vision, mission, and strategic priorities to reflect the evolving nuclear landscape, with a focus on being a trusted, modern regulator and an emphasis on oversight and readiness, supported by talent, efficiency, and culture.
• The CNSC’s new Strategic Plan, guiding internal sequencing and prioritization of work to improve predictability, regulatory clarity, and timely, risk-informed decision-making, particularly as new nuclear projects advance.
• The CNSC’s continued prioritization of regulatory efficiency while maintaining rigor, independence, and safety, including strengthened collaboration with the Impact Assessment Agency of Canada (IAAC) and engagement with the Major Projects Office (MPO) to support integrated and timely project reviews.
• Progress on modernizing the CNSC’s regulatory framework, advancing thematic reviews of regulatory documents, refining reporting requirements, and removing unnecessary regulatory barriers where appropriate.
• Transparency and engagement remaining a core focus for the organization, with expanded public access to information, improved online accessibility, and continued efforts to strengthen engagement with Indigenous Nations and communities, informed in part by feedback from the CNSC’s 2025 Listening Tour.
• Several significant Commission licensing decisions over the past year, demonstrating the CNSC’s continued commitment to transparency, meaningful participation, and ongoing evolution of Commission hearing practices based on feedback from participants and Indigenous Nations and communities.

None of the meeting participants had any questions or comments following Julia’s opening remarks.

Operational management presentation

Update on Regulatory Activity Plans

Tiana Branch provided an overview of the Regulatory Activity Plans (RAPs), including the classes of licensees that are subject to RAPs, and examples of the factors that contribute to the estimated level of effort for planned regulatory activities. Tiana explained what information was included in the RAP packages that licensees received and referenced example documents which had been included in the CRAG’s meeting materials.

Tiana provided an update on the RAP-related activities that had taken place in fiscal year 2024–25:

• On March 31, 2025, the CNSC issued RAPs and fee estimates for fiscal year 2025–26.
• In July 2025, the CNSC issued reports on the number of licensing and compliance activities completed during fiscal year 2024–25. These reports included the number of:
  • licensing decisions for new licences, renewals and licence amendments;
  • Type I and Type II inspections conducted; and
  • orders issued.

Tiana said that the RAPs and fee estimates for fiscal year 2025–27 would be issued no later than Tuesday, March 31, 2026.

• The RAP format and level of detail will remain the same, and RAPs and fee estimates will be issued electronically only.
• No updates were made to the RAP cover letter.

As in previous years, the report on the number of major licensing and compliance activities completed by the CNSC last fiscal year (2025–26) will be provided around the time that final invoices are typically issued, which is in July.

Tiana reminded members that any questions about specific licensing and compliance activities should be directed to the appropriate regulatory program director or project officer, and any questions related to fees should be directed to the CNSC’s finance team.

Discussion

A question was asked by CRAG member Richard Wassenaar concerning the granularity of RAP fees, noting that a more detailed breakdown of what constitutes the internal services costs would be nice to have. Benoit St-Jean noted that this is a question that has been raised during previous CRAG meetings and reiterated that including more granularity in invoicing poses challenges with the whole costing methodology and is not within the financial system’s capacity. Individual licensees can seek more information on specific licensing and compliance activities by communicating directly with their regulatory program director or project officer, but achieving the level of detail described is not feasible. Richard noted that he would take this response back to the industry group he is representing.

Financial management presentation

CNSC financial overview

Ghislain Marcoux began the presentation by providing an overview of the organization’s financial framework and funding sources. He noted that the CNSC continues to meet its mandate to regulate the use of nuclear energy and materials in Canada, including oversight of existing power reactors and the establishment of regulatory frameworks for new and emerging technologies.

Members were informed that approximately 75% of CNSC expenditures are recovered through the Regulatory Activity Plan (RAP), formula, fixed, and special project fees paid by industry. The remaining 25% of expenditures relate to exempt licensees and non-fee-paying activities, including activities associated with international nuclear agreements, and are funded through government appropriations.

Expenditures were described as being largely driven by salaries and employee benefits, which represent approximately 78% of total costs, with the remaining 22% attributable to non-salary goods and services. Ghislain noted that the organization continues to manage fee increases prudently, taking into account ongoing regulatory initiatives and inflationary pressures affecting the cost base.

Regulatory Activity Plans

Ghislain outlined the CNSC’s annual process for developing RAPs for Class I licensees. Members were advised that each RAP is developed through a comprehensive planning exercise that estimates the level of direct regulatory effort required, expressed in full-time equivalent hours, for each licensee.

It was explained that individual RAP fees are determined through a proportional allocation of costs based on planned regulatory activities. The costing methodology allocates common direct, indirect, and internal support costs to direct regulatory effort using an established costing algorithm. These plans and associated costing information are reviewed and validated against prior years.

Ghislain indicated that progress against RAP workplans is monitored quarterly, and adjustments are made as required. For 2026-27, all RAP fee increases were attributed to new build activities and were therefore specific to affected licensees. It was also noted that, historically, year-end RAP fees have often been lower than initial estimates, resulting in refunds to licensees.

Formula fees

An overview of formula fees was provided, including how fees are calculated under Part 3, Schedule 1 of the Cost Recovery Fees Regulations. Members were reminded that formula fees are based on a combination of base hours, a compliance coefficient, and an hourly rate.

Ghislain explained that the hourly rate is reviewed annually in accordance with regulatory requirements. Based on forecasted full costs for 2026-27, the hourly rate for 2026-27 will increase from $311 to $335 per hour, representing an increase of 7.7%, primarily reflecting salary and operating cost increases.

It was noted that formula fee increases are being implemented to address a historical gap between the cost of regulatory activities and revenue recovered through formula fees. Members were informed that this gap was temporarily maintained during the COVID-19 pandemic and that adjustments resumed in the 2025-26 fiscal year. Effective April 1, 2026, formula fees for certain use types will increase by 10%. It was also noted that, since fiscal year 2021-22, formula fee revenues have increased at a slower rate than associated costs, with the difference being funded through appropriations.

Fixed fees

An update was provided on fixed fees and the application of the Service Fees Act (SFA). Members were reminded that only fixed fees under Part 4 of the Cost Recovery Fees Regulations are subject to the SFA, which requires the establishment of service standards, annual fee adjustments based on the Consumer Price Index, and automatic remissions when service standards are not met.

For 2026-27, fixed fees will increase by 1.7% in accordance with the applicable Consumer Price Index adjustment. Ghislain highlighted that, despite annual CPI-based increases, a historical cost-to-revenue gap remains, as these adjustments are insufficient to fully align fixed fee revenues with the underlying program costs.

It was noted that since 2021-22, fixed fee revenues have increased modestly compared to the growth in costs, with the resulting gap being funded through appropriations.

Cost recovery regulations

Ghislain provided an overview of the Cost Recovery Fees Regulations (the regulations) and noted that the regulations came into force in 2003 and have not been substantively updated since that time. Members were advised that the regulations establish licensee categories and determine how regulatory costs are recovered.

Given changes in the nuclear sector and continued growth and diversification of regulated activities, Ghislain indicated that the CNSC is planning a targeted review of the regulations. The purpose of the review is to ensure that the regulations continue to support effective regulatory oversight and are aligned with the evolving nature of the industry and CNSC activities.

Expenditure oversight and dispute resolution mechanism

Ghislain explained that the CNSC continued to review budgets and costs every year to ensure that industry stakeholders received value-for-money with respect to regulatory oversight. The following activities were conducted to ensure this:

• Rigorous operational regulatory planning process;
• CNSC Executive Management committee review;
• Office of the Auditor General review of financial statements, management discussion and analysis; and
• Authority approval by the Treasury Board and Parliament on a yearly basis.

There were regulatory mechanisms in place to resolve any disputes over fee administration or regulatory activity assignments. These mechanisms were outlined and available on the CNSC website – Dispute Resolution Mechanism for Fee Administration and Dispute Resolution Mechanism for Regulatory Activity Assignments.

Discussion

CRAG member Stephen Walker noted that formula and fixed fees continue to increase and asked if the CNSC is exploring ways to control costs, such as by conducting virtual inspections or outsourcing inspections to contractors in closer proximity to licensees across Canada. Karen Owen-Whitred confirmed that the CNSC already conducts virtual inspections where possible and appropriate, such as in instances where an inspection simply constitutes reviewing paperwork. Karen noted that virtual inspection experience was gained during the height of the COVID-19 pandemic when the CNSC had to conduct the majority of inspections virtually. Karen also explained that there is no replacement for many on-site inspections (whether those be related to compliance promotion, or with licensees that the CNSC does not see for years at a time due to risk ranking). On-site presence is critical to ensure compliance, which is why the CNSC cannot and will not defer to conducting the majority of inspections virtually.

Benoit St-Jean added to Karen’s response and noted that the fees charged through formula fees are fully loaded costs, meaning they represent the CNSC’s regulatory effort beyond inspection and compliance work, such as regulatory framework effort, Commission hearings, and other internal services. The CNSC is focusing on controlling costs and finding efficiencies, such as capping travel costs to ensure there is no travel expenditure growth, as well as analyzing professional services costs and controlling those. Benoit noted that most of the CNSC’s costs are driven by salaries.

Stephen asked again if the CNSC would consider outsourcing for low complexity work, such as routine inspections, or leveraging artificial intelligence (AI) tools to realize any cost savings. Karen responded by noting that it is unclear what benefit outsourcing direct licensing and compliance work may have with respect to cost savings, given that the CNSC uses a risk-informed approach, and some low risk use types are inspected on an “if available” or “as needed” basis. Often, inspectors may visit licensees if they are already in the area for other compliance work. She also confirmed that the CNSC continues to explore new ways of using available digital tools, including AI, to add efficiencies.

CRAG member Sean Hunt echoed Stephen’s question about leveraging AI to conduct assessment activities, which would otherwise be performed by a salaried FTE. Karen confirmed again that the CNSC is leveraging AI where appropriate, including for annual compliance reports. Sylvain Faille supplemented Karen’s response, by noting that the CNSC is trying to streamline the process for reviewing annual compliance reports, and looking at the information in CNSC databases to see if there are components of the data that the system could analyze and report on, and then staff could review based on anything that the system flagged. This remains at the conceptual stage and may be expanded to other parts of the assessment in the future.

Geneviève Boudrias acknowledged the interest from members in learning about what CNSC is doing in the space of regulatory efficiency and noted that the CNSC is hosting a collaborative roundtable with all interested parties including industry on April 2, 2026, to discuss regulatory efficiency. She welcomed members to attend if they are not signed up already, and noted that the CNSC will publish a “What We Heard” report after the session and use that to further inform CNSC work plans going forward.

Maury Burton acknowledged that formula and fixed fees are increasing and noted that even if similar increases are implemented over the next several years, it’s evident that the cost-revenue gap will not close. He raised that smaller companies who are subject to these rising fees will begin to suffer with year-over-year increases. He asked where the CNSC plans on going in the next 5 to 10 years to address this and close the gap.

Benoit responded by noting that reviewing and amending the Cost Recovery Fees Regulations (the regulations) will enable the CNSC to revisit the methodologies behind its cost recovery regime and make adjustments to better reflect the evolution of regulatory activities since the regulations were introduced in 2003. He also noted that fixed fees present such a large gap because of the Service Fees Act limiting yearly increases to that of the consumer price index increases. Again, this can only be addressed by reviewing the regulations. He reinforced, however, that the gap is unlikely to fully close, especially on the formula fee side. Karen echoed this, noting that appropriated funding will always be used for the fee-exempt licensees and activities.

Finally, CRAG member Richard Wassenaar asked for clarification regarding the formula fee increase. Benoit explained that formula fees are calculated using a prescribed formula consisting of base and variable hours, multiplied by the CNSC’s hourly rate. He confirmed that effective April 1, 2026, the variable and base hours will increase by 10%, while the hourly rate will increase by 7.7%.

Other business

Updated CRAG Terms of Reference

Julia followed up on an action from last year’s meeting to revisit the CRAG Terms of Reference (ToR), which had not been updated since 2007. Julia confirmed that the ToR have been re-drafted, and thanked all CRAG members for engaging in a formal review and comment period on the draft in February 2025. Julia noted that the ToR are currently referred to the CNSC’s Executive Team for final review and approval, and that the CRAG Secretary will ensure members remain informed of the status of that review when a decision is made.

CRAG member terms and renewals

Julia acknowledged that an updated process for CRAG member terms and renewals is outlined in the updated ToR. She explained that this change was introduced to better organize and formalize the way in which CRAG membership is maintained, and to streamline the actioning of any updates by the CRAG Secretary. Julia confirmed that member terms and renewals will run in line with the CNSC’s fiscal year (April 1 through March 31) to help ensure that proposed changes to membership can be prompted and discussed with the CRAG Secretary during the coordination of the annual CRAG meetings. April 1, 2026, will mark the beginning of the current members’ two-year terms, and renewals will be discussed at the appropriate time for terms beginning or renewing on April 1, 2028.

CRAG member Richard Wassenaar asked whether there is a set process in place if a new member is to be appointed, and what role a departing CRAG member has in the process. CRAG Secretary Sarah Kelly outlined the internal process followed for identifying and appointing new members, noting that the best-case scenario is working with the departing CRAG member to identify a replacement representative, if that opportunity is available. The internal process consists of working with the relevant licensing group within the CNSC to identify potential new members and submitting the final recommendation to the CRAG Chair for final decision.

Other

CRAG member Richard Wassenaar asked if the meeting materials circulating to members can be shared, to which the CRAG Secretary confirmed that yes, there are no limitations on sharing the materials.

Concluding comments and next meeting

Julia thanked the CRAG members for their participation and confirmed that the next meeting would tentatively be held in March 2027. Julia adjourned the meeting.

Actions

1. Meeting minutes would be sent to the CRAG members for review as soon as possible after the meeting, ideally within a month, and the CNSC would aim to post the minutes online within a maximum of 3 months.
2. CRAG Secretary will inform CRAG members of the CNSC’s Executive Team approval of the new CRAG Terms of Reference once a decision has been made.