Red Tape Review

The Canadian Nuclear Safety Commission (CNSC) regulates the use of nuclear energy and materials to protect health, safety, security, and the environment; to implement Canada’s international commitments on the peaceful use of nuclear energy; and to disseminate objective scientific, technical, and regulatory information to the public.

In July 2025, the Government of Canada launched an initiative to reduce regulatory red tape, including complicated or outdated processes; unnecessary, duplicative, or overly burdensome rules; or inefficient or unpredictable regulatory administration or service delivery. Through this exercise, the Government seeks to advance the modernization of the federal regulatory framework.

Executive Summary

The CNSC is committed to maintaining a regulatory framework that is not only effective and evidence-based, but also efficient and responsive to evolving needs. As part of this commitment, the CNSC continually reviews its regulations and practices to identify and address those that may be outdated, duplicative, or unnecessarily burdensome – ensuring that regulatory oversight remains clear, modern, and fit for purpose. The goal is to modernize the regulatory system while maintaining strong protections regarding health, safety, and the environment, supporting the goals of this government initiative, and fulfilling Canada’s international obligations in nuclear safety and security. Regulatory modernization at the CNSC refers to the process of updating, streamlining, aligning, and improving regulatory frameworks, regulatory approaches, and regulatory processes to make them more efficient, effective, and adaptable to current and future challenges.

Regulatory modernization involves revising outdated rules, reviewing how frameworks work together, harmonizing where appropriate, reducing unnecessary bureaucracy, leveraging technology for better enforcement and compliance, implementing modern regulatory drafting approaches, and ensuring that regulations keep pace with social, economic, and technological changes.

The CNSC’s modernization efforts are guided by key drivers: enhancing transparency and engagement, applying lessons learned from events such as the Fukushima Daiichi nuclear accident, and preparing for emerging technologies by means of technology-neutral requirements and clear guidance for applicants. Incidents such as the Fukushima Daiichi nuclear accident and the September 11 terrorist attacks have led to substantial evolution in global nuclear regulatory frameworks, prompting more stringent safety, security, and emergency preparedness requirements. In addition, the introduction of novel technologies such as small modular reactors (SMRs) has required us to review regulations and regulatory documents. In response, the CNSC continually adapts its regulatory framework and approach to ensure robust oversight of Canada’s nuclear sector.

It is through these modernization initiatives that the CNSC can best address the reduction of red tape and regulatory inefficiencies. To date, the CNSC has made quantifiable progress across its key regulatory modernization initiatives.

• Completed:
  • From 2013 to 2023, the CNSC consolidated over 150 legacy documents into just over 70 REGDOCs, representing an approximate 50% decrease in the number of regulatory documents.
  • The CNSC streamlined its consultation by eliminating the “feedback on comments period” for regulatory consultations, shortening timelines by 6 to 8 weeks per project while preserving the highest levels of transparency and engagement with interested parties. This change represents an overall reduction of 30–40% in consultation timelines.
• Nearing Completion:
  • The CNSC is making amendments to the General Nuclear Safety and Control Regulations and the Nuclear Non-proliferation Import and Export Control Regulations aligning with updated international controls, introducing new license exemptions and reducing unnecessary requirements. These combined regulatory amendments are estimated to have a net benefit of $500K per year to implicated businesses. There is also an expected $1M savings to the Government from the proposed exemptions given the reduction in the licence application for the exempted low-proliferation nuclear materials.
  • The CNSC undertook a regulatory project to repeal and replace the Nuclear Security Regulations. One of the key benefits from this regulatory proposal is elimination of potential regulatory barriers to the development and deployment of new technology in Canada – supporting innovation and contributing directly to red tape reduction.

Along with the initiatives outlined in this review, the CNSC will continue to implement its regulatory framework plan and its regulatory review plan, which covers 20 separate regulations and REGDOC themes over the next 10 years. Conducting scheduled and systematic reviews of regulations and regulatory frameworks can support efficiencies, reduce costs, and improve opportunities for growth and innovation while strengthening underlying policy objectives. By adopting a thematic approach, the CNSC can work to identify and address overlaps and redundancies across the regulatory framework. The CNSC regulatory review process ensures that Canada continues to have regulatory instruments that set out clear expectations for licensees, the public, Indigenous Nations and communities, and other interested parties. These reviews focus on modernizing the regulatory framework to reflect the latest domestic and international developments in nuclear safety and security.

Advancing National Priorities and Major Projects

Getting major projects built in Canada is a priority. Federal departments and agencies have been reviewing policies and practices to accelerate decision making and improve the delivery of assessments, permits, licences, and authorizations for major projects. Under the instruction of the Cabinet Directive on Regulatory and Permitting Efficiency, and as coordinated by the Clean Growth Office in the Privy Council Office, the CNSC has been working with other federal departments to develop permitting plans, coordinate Crown consultations, and increase collaboration with proponents to improve coordination. Specifically, the CNSC has been working closely with the Impact Assessment Agency of Canada to integrate the CNSC’s licensing process for nuclear projects that fall under the Physical Activities Regulations into the integrated impact assessment process, in keeping with “one project, one review”.

On June 26, the Building Canada Act received royal assent, empowering the government to accelerate nation-building projects in consultation with Indigenous Peoples. The CNSC is committed to supporting its implementation while protecting environmental integrity and Indigenous rights and building relationships and opportunities for economic partnerships with Indigenous Peoples.

In the Speech from the Throne, the government committed to establishing a Major Federal Projects Office to achieve project reviews and decisions within 2 years. The CNSC will support the Office and collaborate with partners across government to enable this outcome with its own policies, practices, and regulations. This includes reviewing the CNSC’s regulations related to major project reviews.

Progress Achieved and Underway

The CNSC’s approach to modernization can be organized into three pillars:

1. Modernizing regulations and regulatory frameworks
2. Modernizing regulatory approaches and authorities
3. Modernizing regulatory development processes

Each pillar represents a key area of focus. Together, these three pillars create a comprehensive approach to regulatory modernization, promoting efficiency, responsiveness, and innovation while safeguarding public interests. These initiatives are interconnected, each contributing to a cohesive and adaptive regulatory modernization strategy. Through its Regulatory Modernization approach, the CNSC has completed, or is progressing on, the following initiatives:

• Modernizing regulations and regulatory frameworks – review and revise regulations and broad regulatory thematic frameworks – looks at what we regulate and how we regulate it
  • 1. Review the Packaging and Transport of Nuclear Substances Regulations as part of the broader Supply Chain Regulatory Review coordinated by the Treasury Board of Canada Secretariat – ONGOING
  • 2. Amend the Nuclear Security Regulations based on commitments in the Small Modular Reactor Action Plan – NEARING COMPLETION
  • 3. Amend the General Nuclear Safety and Control Regulations and the Nuclear Non-proliferation Import and Export Control Regulations – NEARING COMPLETION
• Modernizing regulatory approaches and authorities – looks at how we approach regulation broadly as a lifecycle regulator, and overall efficiencies in the regulatory system
  • 4. Modernize and streamline the CNSC regulatory framework, including shifting the approach to the review under broad safety and control areas – ONGOING
  • 5. Develop an internal process guide (COMPLETE) and external policy (ONGOING) for the use of incorporation by reference
  • 6. Create a Regulatory Modernization Division (COMPLETE); and an overarching organization-wide regulatory modernization strategy – NEARING COMPLETION
• Modernizing regulatory development processes – looks at finding efficiencies in how we operate as a regulator, and at internal and external processes in developing and administering regulations
  • 7. Develop an internal REGDOC digital library – COMPLETE
  • 8. Eliminate the “feedback on comments period” during regulatory and REGDOC development – COMPLETE
  • 9. Establish engagement meetings with regulated parties and other interested parties specifically on regulatory framework efficiencies – ONGOING

Item 1: Review the Packaging and Transport of Nuclear Substances Regulations – Ongoing

Context

In Canada, the packaging and transport of nuclear substances and radiation devices are regulated by the CNSC in accordance with the Packaging and Transport of Nuclear Substances Regulations, 2015 (PTNSR 2015) made under the Nuclear Safety and Control Act.

Through the Supply Chain Regulatory Review consultation, interested parties called for Canada to align the classification of low specific activity-I (LSA-I) material, particularly uranium and thorium ores, with international regulations, specifically the International Atomic Energy Agency (IAEA) Regulations for the Safe Transport of Radioactive Material (SSR-6), in order to facilitate their transport across the border. Canada, through the PTNSR 2015, requires the use of more robust packages for uranium and thorium ores exceeding 3% in concentration, which is not the case in other jurisdictions. Stakeholders have highlighted that a lack of alignment imposes a burden on Canadian companies and reduces international competitiveness.

Actions

The CNSC is proposing to update the PTNSR 2015. In spring 2024, the CNSC published a discussion paper, seeking stakeholder views on proposed amendments that would seek to align requirements with the Radiation Protection Regulations, amend existing requirements, and add new licensing requirements. CNSC staff are currently considering all feedback, including what was received through the Supply Chain Regulatory Review consultation on international alignment for LSA-I material.

Outcomes and milestones

Proposed amendments to the PTNSR 2015 are expected to be published in the Canada Gazette, Part I, in spring 2027. The proposal includes potential changes that aim to reduce the costs associated with the transport of LSA-I material and facilitate its transport across the border, thus supporting Canada’s international competitiveness in the global uranium market. Any amendments put forward will ensure that the PTNSR 2015 continue to prevent unreasonable risk to the health and safety of workers, the public, and the environment.

Item 2: Amend the Nuclear Security Regulations based on commitments in the Small Modular Reactor Action Plan – Nearing completion

Context

Small modular reactors (SMRs) are a new class of nuclear reactors that are considerably smaller in size and power output than traditional nuclear power reactors, often with enhanced safety features. The CNSC participated in the development of Canada’s SMR Action Plan. While the CNSC has a flexible regulatory framework for the licensing and oversight of innovative nuclear technologies, it continues to review its framework for opportunities to clarify and improve it. This includes ensuring that its regulatory framework is technology-neutral and adaptable to new technologies proposed in Canada.

Actions

The CNSC identified that there are potential regulatory barriers in the Nuclear Security Regulations (NSR) to the adoption of new technology. The CNSC started a review of the NSR in 2018 with the goal of making them more performance-based and less prescriptive while respecting nuclear security principles. After the broad review, the CNSC undertook a regulatory project to repeal and replace the NSR. With respect to SMRs, the proposal would remove barriers to development and deployment of new reactor designs and technologies as per the CNSC’s commitments in Canada's Small Modular Reactor (SMR) Action Plan and A Call to Action: A Canadian Roadmap for Small Modular Reactors.

Outcomes and milestones

One of the key benefits from this regulatory proposal is elimination of potential regulatory barriers to the development and deployment of new technology in Canada — supporting innovation and contributing directly to red tape reduction. This change is an important part of a broad initiative to promote SMR deployment in Canada. In addition, this regulatory proposal would fulfill one of the CNSC commitments identified in the SMR Action Plan on the modernization of the existing NSR.

The regulatory proposal was pre-published in the Canada Gazette, Part I, on November 12, 2022. The CNSC is anticipating final publication in the Canada Gazette, Part II, in fall/winter 2025.

Item 3: Amend the General Nuclear Safety and Control Regulations and the Nuclear Non-proliferation Import and Export Control Regulations – Nearing completion

Context

Canada has international obligations related to nuclear non-proliferation that are implemented domestically through Canadian regulations, specifically the General Nuclear Safety and Control Regulations (GNSCR) and the Nuclear Non-proliferation Import and Export Control Regulations NNIECR). Misalignment between these regulations and the implementation of international agreements hinders Canada’s ability to meet the commitments it has made to the peaceful use of nuclear energy. In addition, some of the requirements on regulated parties in those two regulations are duplicative and inefficient related to the import and export of prescribed information, and for the import and export of very low risk substances.

Actions

The CNSC is proposing to update the GNSCR to add requirements related to safeguards to align with Canada’s treaty-level safeguards obligations. Specifically, the proposed changes would introduce new requirements for any person either possessing small amounts of nuclear material or engaged in nuclear fuel cycle-related research and development and/or in nuclear-related manufacturing activities. The proposed amendments would also include lifting the need to present a licence at the border when exporting or importing prescribed information.

The CNSC is also proposing to update the NNIECR to include the latest revisions to international control lists, introduce new licence exemptions, enhance licensing information, and harmonize record retention periods. Amending the GNSCR and the NNIECR would ensure Canada’s regulatory framework is aligned with its safeguards agreements and internationally agreed export controls. It would also support the CNSC’s responsibilities with respect to the oversight of nuclear materials, nuclear fuel cycle-related research and development and nuclear-related manufacturing, as well as the export of controlled nuclear substances, equipment, and information.

Outcomes and milestones

The amendments include changes that reduce burden and inefficiencies. Exporters/importers have moved away from transmitting prescribed information using physical formats and now share that information digitally. Currently, the GNSCR require licensees to present a copy of their CNSC licence to a Canada Border Services Agency customs officer when exporting/importing prescribed information (for example, plans, engineering designs, manuals, or instructions), regardless of the format. The proposed regulations would eliminate the requirement for licensees to present a CNSC licence to customs officers when importing or exporting prescribed information to or from Canada.

Proposed amendments in the NNIECR would introduce exemptions in the NNIECR for items considered to be of very low risk to contribute to nuclear weapons development, such as tritium contained in self-luminous devices for personal use, watches, and compasses. The proposed amendments would no longer require a person to obtain a licence to export or import such items. These combined regulatory amendments are estimated to have a net benefit of $500K per year for implicated businesses. There is also an expected $1M in savings to the Government from the proposed exemptions given the reduction in the licence applications process for the exempted low-proliferation nuclear materials.

The regulatory proposal was pre-published in the Canada Gazette, Part I, on March 30, 2024. The CNSC is anticipating final publication in the Canada Gazette, Part II, in fall/winter 2025.

Item 4: Modernize and streamline the CNSC regulatory framework – Completed and moving into implementation

Context

In 2010, the CNSC outlined a long-term vision for its regulatory framework to better serve licensees and staff. Building on this, a comprehensive modernization initiative was launched in 2013, introducing the regulatory document (REGDOC) series of materials supporting the regulatory framework.

Actions

The initiative consolidated requirements and guidance into single documents where practical, grouped related topics for easier access, and implemented a five-year review cycle.

During this initiative, emerging technologies and global events were addressed by:

• launching multiple regulatory document review projects to support SMR readiness
• establishing a working group to assess the regulatory impact of disruptive, innovative, and emerging technologies (DIET) and develop an evergreen response strategy
• updating several REGDOCs to incorporate lessons from the 2011 Fukushima incident
• working collaboratively with interested parties, including the regulated community, with a focus on improving the regulatory framework and approaches to ensure that they are efficient, effective, and adaptable to emerging challenges

Outcomes and milestones

This multi-year and multifaceted approach streamlined and reduced over 150 legacy documents to just over 70 REGDOCs, representing an approximate 50% decrease in the number of regulatory documents. As of 2024, the move to implement a modern regulatory framework has concluded, and the CNSC has initiated its shift to a thematic review approach, moving from isolated REGDOC revisions to cross-cutting analyses across multiple documents. This holistic method ensures consistent regulatory treatment and alignment across regulations, reduces duplication, ensures that the CNSC’s regulatory framework is fit for purpose, capitalizes on integrating our operational experience, and limits stand-alone projects. The CNSC has adopted a lifecycle approach to its catalogue of published regulations and documents. Going forward, the review of regulatory stock and supporting REGDOCS will be done by safety and control area.

Item 5: Develop an internal process guide (complete) and external policy (ongoing) for the use of incorporation by reference

Context

Along with its many regulations and regulatory documents, the CNSC’s regulatory framework also consists of standards and other documents incorporated by reference into the regulations and REGDOCs themselves. The use of incorporation by reference (IBR) provides CNSC staff with a means to reference existing documents (such as external CSA Group standards and IAEA documents) in the CNSC’s regulatory framework and avoid unnecessary replication, reproduction, paraphrasing, and duplication of requirements. Operating experience from the development of regulations and REGDOCs has demonstrated several issues with current practices related to the use of IBR, including consistent application and clear responsibilities when incorporated documents are updated.

Actions

The CNSC initiated the development of an internal process guide on the use of IBR in its regulations and REGDOCs to support its effective and consistent use by CNSC staff, and initiated development of an external policy on IBR, which can demonstrate to regulated parties how the CNSC uses IBR efficiently, effectively, and responsibly. IBR, when used effectively, can keep regulatory frameworks nimble and up to date, without having to amend regulations. The regulatory framework is more responsive by incorporating documents such as CSA Group standards and IAEA documents within our regulatory instruments.

Outcomes and milestones

The internal process guide on the use of IBR was completed in February 2025 and now will be part of the development approach for all regulatory and REGDOC projects. The process guide will serve as a basis for an external Incorporation by Reference Policy, to demonstrate to regulated parties that the CNSC uses IBR responsibly.

The external IBR Policy will be completed in 2025–26 and posted on the CNSC’s website. Having a clear and well-understood approach in place for the use of IBR in regulations and REGDOCs will help streamline the development process as well as help to reduce duplication and overlap of requirements.

Item 6: Create a Regulatory Modernization Division – Complete; and an overarching organization-wide regulatory modernization strategy – Nearing completion

Context

As a lifecycle regulator with broad regulatory responsibilities, the CNSC invests considerably in the day-to-day business of regulating (revising and reviewing regulations and REGDOCs, inspecting and enforcing compliance, and working with regulated parties). This focus could limit opportunities for broad regulatory improvements, including enhancing efficiencies and collaborating with other federal regulators on improvements to regulatory approaches.

Actions

To ensure it remains at the forefront of regulatory best practices and regulatory modernization initiatives, both at home and abroad, the CNSC established a dedicated division within the Regulatory Policy Directorate to lead and coordinate regulatory modernization efforts across the organization. The Regulatory Modernization team examines initiatives from the Treasury Board of Canada Secretariat international regulatory partners, and other regulatory departments and agencies, and establishes a regulatory modernization strategy supported by a 2-year evergreen plan for the CNSC. This positions the CNSC to take swift and appropriate action on modernization initiatives that could directly affect regulatory efficiency and reduce burden.

Outcomes and milestones

The Regulatory Modernization team was created in 2024–25. The new team is now finalizing the development of a regulatory modernization strategy for the CNSC. This strategy will guide the CNSC’s interactions with new regulatory initiatives as well as help internally assess and prioritize potential new projects, with an eye to how they will help alleviate and reduce regulatory burden and inefficiencies. Having this strategy in place will guide the CNSC’s actions on regulatory burden and inefficiency reduction and help assess potential new initiatives and their impacts. The strategy will be finalized in fall 2025.

Item 7: Develop an internal REGDOC digital library – Complete

Context

Maintaining over 70 REGDOCs to guide the nuclear industry’s compliance with regulations is complex, and administrative issues with keeping documents up to date and ensuring alignment across REGDOCs can have direct impact on regulated parties. Because of the nature of CNSC licensing activities, different regulated parties may be required to conform to different versions of the same REGDOC, depending on the contents of their licence. Internal version control and any challenges with the propagation of revisions and amendments across multiple documents can have direct, serious administrative burden consequences for regulated parties. Traditional document drafting and control methods are not enough to deal with the complexity of the situation.

Actions

The CNSC initiated the creation of an internal digital document platform and library, which serves as a content management platform, a document authoring manager, and a tool to oversee linkages between different documents. This digital platform modernizes the CNSC’s regulatory policy infrastructure by making regulatory information easier to find and easier to re-use and maintain. To enable this transformation, the project deploys new technology and a structured authoring tool, and explores new approaches to create, manage, and present regulatory information.

Outcomes and milestones

The internal digital REGDOC tool has been developed and deployed internally, and regulatory officers are already using the tool in drafting new and revised REGDOCs, helping to reduce and eliminate any administrative burden issues that may arise for regulated parties from version control. Having such a tool as part of the development process will ensure consistency of approach and wording across the regulatory framework and will support removing any duplication in the REGDOCs. It also supports identifying any conflicts or overlaps between requirements across regulatory frameworks and the supporting REGDOCs. Future enhancements to the tool are possible.

Item 8: Eliminate the “feedback on comments period” during regulatory and REGDOC development – Complete

Context

For more than 15 years, the CNSC’s consultation program has had two feedback periods. During the first period, the CNSC invites interested parties to provide feedback on draft REGDOCs, discussion papers, position papers, and the regulatory framework plan. The CNSC receives, dispositions, and posts these comments. During the second feedback period, the CNSC invites interested parties to provide feedback on the comments received during the initial consultation period. The CNSC was one of the only federal regulatory bodies that had this second “feedback on comments” period as part of their regulatory consultation process.

Actions

A review of the feedback received in that second consultation period showed that, since 2019, there has been a significant decrease in its usage. Further, the feedback received rarely provided new or substantive information, while adding to the overall length of time that it took to complete the regulatory project. This extra period of comment time delayed the conclusion of projects without any significant positive impact on the process or the final product.

Outcomes and milestones
The CNSC streamlined its consultations by eliminating the “feedback on comment period” for regulatory consultations, shortening timelines by 6 to 8 weeks on the development of regulatory projects – an overall reduction of 30–40% in consultation timelines – while preserving the highest levels of transparency and engagement with interested parties. This change took effect July 1, 2025, and key interested parties were informed ahead of time.

Item 9: Establish engagement meetings with regulated parties and other interested parties specifically on regulatory framework efficiencies – Ongoing

Context

The CNSC has a varied and diverse set of interested parties in its regulatory framework, such as large-scale nuclear energy facilities; hospitals using nuclear imaging technology; uranium mining and milling facilities; environmental non-governmental organizations; communities with nuclear facilities; and Indigenous Nations and communities. The CNSC has a robust and thorough engagement process with interested parties, and the Commission proceedings provide a public forum for engagement and discussion on relevant issues. Industry representatives and associations have expressed a desire to further engage in dialogue with the CNSC to discuss regulatory efficiency and burden.

Actions

The CNSC will develop a plan and approach for holding engagement meetings related specifically to exploring and discussing regulatory efficiencies with interested parties. The CNSC will weigh all input from interested parties on opportunities for further regulatory streamlining, without compromising on its mandate.

Outcomes and milestones

These meetings will provide an opportunity to examine the underlying issues and context behind the concerns of regulated parties and other interested parties, and to explore potential opportunities to streamline regulatory requirements, where appropriate. These engagement meetings will be important in identifying and prioritizing new areas of improvement, which could then be incorporated as part of the CNSC’s Red Tape Reduction initiatives.

An initial meeting with the Canadian Nuclear Association (CNA) Regulatory Affairs Advisory Committee will occur in September 2025. Further to that, a detailed plan for future engagement meetings and associated actions/commitments on regulatory efficiencies will be established in fall/winter 2025.

Conclusion

Summary of status of initiatives by pillar

1. Modernizing regulations and regulatory frameworks – 1 ongoing and 2 nearing completion
2. Modernizing regulatory approaches and authorities – 2 ongoing, 1 nearing completion and 2 completed initiatives
3. Modernizing regulatory development processes – 1 ongoing and 2 completed initiatives

The CNSC advances regulatory modernization through a range of initiatives that aim to reduce regulatory burden without compromising on its mandate to regulate the use of nuclear energy and materials to protect health, safety, security, and the environment; to implement Canada’s international commitments on the peaceful use of nuclear energy; and to disseminate objective scientific, technical, and regulatory information to the public. Working collaboratively with interested parties, including the regulated community, the CNSC focuses on improving its regulatory framework and approaches to ensure that they are efficient, effective, and adaptable to emerging challenges. These efforts support innovation through regulatory experimentation and strengthen alignment with Canada’s broader federal regulatory community and international counterparts.