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National paper of Canada on the implementation of the Code of Conduct on the Safety and Security of Radioactive Sources 2026

Executive Summary

This paper provides a summary of Canada’s continuing efforts related to the implementation of the International Atomic Energy Agency (IAEA) Code of Conduct on the Safety and Security of Radioactive Sources, Guidance on the Import and Export of Radioactive Sources and Guidance on the Management of Disused Radioactive Sources for the period of January 2023 to December 2025.

Canada has a well-established, risk-informed regulatory framework for the control of Category 1 and 2 radioactive sources, which is the focus of this paper, as well as for Category 3, 4 and 5 radioactive sources. This includes legislation and regulations addressing the safety and security of radioactive sources, a comprehensive system of licensing, compliance verification, a Sealed Source Tracking System, a National Sealed Source Registry, and import and export controls.

Through the regulatory framework, the Canadian Nuclear Safety Commission (CNSC) has established regulatory controls and measures from the production of radioactive sources to their final disposition including a process for bringing orphaned sources back under regulatory control, effectively controlling radioactive sources throughout their lifecycle. Key enhancements of regulatory controls related to Category 1 and 2 radioactive sources during the reporting period, include:

In updating its regulations and regulatory framework, the CNSC has continued to modernize its regulatory approach through stakeholder and Indigenous engagement, reducing regulatory burden and improving readiness for new technologies while maintaining strong safety and security.

A. Infrastructure for regulatory control of the safety and security of radioactive sources

A.1 Legislation and regulations

At the top level of Canada’s nuclear regulatory framework is the Nuclear Safety and Control Act (NSCA). It came into force on 31 May 2000 and provides the Canadian Nuclear Safety Commission (CNSC) with its regulatory authority. Under the NSCA, the CNSC’s mandate is to regulate:

  • the development, production and use of nuclear energy
  • the production, possession and use of nuclear substances, prescribed equipment and prescribed information in order to prevent unreasonable risk to the environment, to the health and safety of persons and to national security to achieve conformity with Canada’s international commitments on the peaceful use of nuclear energy

The CNSC has a clear, pragmatic and comprehensive regulatory framework for facilities and activities authorized under the NSCA, which ensures effective regulatory oversight of radioactive sources from the stage of initial production to their final disposition. This regulatory framework encompasses not only the NSCA and its regulations, licences and certificates, but also regulatory documents and bilateral arrangements with domestic and foreign authorities.

The CNSC’s regulatory system is based on risk-informed licensing and compliance verification processes which require licensees and other persons regulated under the NSCA to demonstrate that their activities are safe and secure. By implementing a risk-informed regulatory approach, the CNSC:

  • regulates in a manner that is consistent with the risk posed by the facilities and activities
  • recognizes that risk must be considered in the context of the CNSC’s duties and responsibilities under the NSCA
  • makes regulatory decisions and allocates resources in a risk-informed manner
  • provides guidance, indicates acceptable ways to meet regulatory requirements, and allows licensees to propose alternative methods

Achievements and planned improvements

In October 2023, Transport Canada’s Transportation of Dangerous Goods Regulations were amended to introduce a registration database for those who import, offer for transport, handle, or transport all dangerous goods, including Category 1 and 2 radioactive sources, in Canada. These amendments support improved interdepartmental coordination and information visibility for CNSC-regulated licensees subject to requirements for transportation of dangerous goods.

Canada hosted an IAEA Integrated Regulatory Review Service (IRRS) follow-up mission from June 4 to 10, 2024, a follow-up to the original mission which occurred in 2019.  Overall, this follow-up mission concluded that Canada has made substantial progress in addressing the recommendations and suggestions arising from the 2019 IRRS mission, confirming the continued strength and effectiveness of Canada’s nuclear and radiation safety regulatory framework and its commitment to continuous improvement.  The IAEA highlighted that notable achievements had been made in:

  • the radioactive waste management framework through the publication of the Integrated Strategy for Radioactive Waste and the revision of Canada’s Policy for Radioactive Waste Management and Decommissioning
  • the conduct and processes for inspections of facilities and activities through further formalization of the CNSC programme guidance
  • the consolidation of the CNSC’s safety policy elements and the development of a process for performing regulatory policy review and analysis
  • the revision and publication of regulatory and guidance documents in the areas of the transport of nuclear and radioactive materials and fuel cycle facilities, so that they are consistent with IAEA safety standards

In support of its vision to be a world-class regulator that maintains a strong safety culture, the CNSC chose to undergo an IAEA-led Independent Safety Culture Assessment (ISCA) In September 2024. As part of its renewed strategic plan and priorities, the CNSC has identified several actions to address recommendations and suggestions raised in the ISCA. These actions aim to improve the understanding and practice of safety culture within the CNSC and strengthen the role the CNSC plays in influencing the safety culture of licence holders. CNSC actions to enhance safety culture include:

  • review and update of the current Regulatory Safety Culture Policy
  • communication and promotion of the importance of regulatory safety culture and its enablers
  • annual communication to all employees on CNSC’s safety culture activities

In October 2025, the Nuclear Security Regulations (NSR) were published, replacing the previously repealed NSR and with transitional provisions coming into force on October 30, 2027. The newly published NSR introduce a significant enhancement through an expanded focus on “other nuclear substances”, beyond those identified as nuclear materials. These new requirements establish specific requirements for licensees to prevent the loss, unauthorized use, possession, or removal of radioactive sources with an activity level greater than or equal to 10 times the D-value for the substance, when such radioactive sources are located within areas of a nuclear facility. These new requirements are in addition to existing CNSC requirements and expectations that state licensees must implement graduated risk-informed security measures for all radioactive sources in areas inside and outside nuclear facilities.

The Nuclear Substances and Radiation Devices Regulations (NSRDR) are currently under review. One of the anticipated changes is to introduce an ambulatory incorporation by reference to table I.1 of the IAEA’s General Safety Requirements Part 3 to preclude the requirement to update the NSRDR periodically.

The Class II Nuclear Facility and Prescribed Equipment Regulations are under review, with proposed changes that would require applicants to provide a proposed disposal method for Class II prescribed equipment at the time of construction or initial licensing, and to identify design-stage measures for securing equipment containing nuclear substances. Licensees would also be required to describe how they will comply with safeguards agreements in applications to construct facilities possessing safeguarded material, with ongoing compliance addressed through licence conditions. During the reporting period, the CNSC engaged stakeholders through an information session, a What We Heard report, conference presentations, and targeted outreach to Indigenous Nations and communities. Overall, stakeholders supported the proposed changes but raised implementation concerns, including the treatment of previously certified equipment and the potential for disposal methods to change over time. A grandfather clause for existing equipment is being considered, and the CNSC recognizes that disposal plans may evolve while emphasizing the need for lifecycle planning.

The Packaging and Transport of Nuclear Substances Regulations, 2015 are currently under review, and one of the anticipated amendments would introduce a new licensing requirement for the transport of nuclear substances in conveyances where no person is physically present, such as driverless vehicles or remotely piloted aircraft systems (drones). This proposed change is informed by the successful completion of a pilot project in spring 2023, which involved the transport of single-use medical isotopes by drone. This amendment is intended to codify regulatory oversight of emerging transport technologies, support CNSC awareness and compliance, and ensure preparedness for their potential use, including in emergency response scenarios.

The CNSC is currently reviewing and restructuring the 2.12 series of nuclear security regulatory documents, including REGDOC-2.12.3, Security of Nuclear Substances: Sealed Sources and Category I, II and III Nuclear Material, which establishes minimum security measures to prevent the loss, sabotage, unauthorized use, possession, or removal of sealed sources during transport or while in storage located outside nuclear facilities, to align with amendments made in the new Nuclear Security Regulations.  REGDOC-2.12.3 is aligned with the Code, as well as with the IAEA Nuclear Security Series No. 14, Nuclear Security Recommendations on Radioactive Material and Associated Facilities.

A.2 Establishment and responsibilities of the regulatory body

The CNSC is a “3S” nuclear regulator: it is responsible for nuclear safety, security and safeguards. CNSC safety and security staff work closely together to harmonize and integrate safety, security, and safeguards requirements and measures where possible (taking into account Canada’s international obligations and safeguards agreements). The CNSC recognizes the importance of safety, security and safeguards in all aspects of its regulatory oversight. In fact, the CNSC is one of the few regulators that is solely responsible for all three. The CNSC regulates the use of nuclear energy, material and substances to protect health, safety, security and the environment. It also implements Canada’s international commitments on the peaceful use of nuclear energy and disseminates objective scientific, technical and regulatory information to the public.

The NSCA established the CNSC in 2000, under paragraph 8(1), to replace the former Atomic Energy Control Board (AECB). The CNSC reports to Parliament through the Minister of Natural Resources on the Commission’s activities under the Act. Decisions made by the Commission are not subject to government or political review and cannot be overturned by the Government of Canada. Only the Federal Court or the Supreme Court of Canada may review and overrule a decision made by the Commission.

The CNSC’s Commission has up to 7 appointed permanent members whose decisions are supported by 1,124 staff members as of December 31, 2025. CNSC staff review applications for licences according to regulatory requirements, in alignment with the IAEA standards and guidance, and in consideration of industry and international best practices; make recommendations to the Commission or Designated Officer (DO); and enforce compliance with the NSCA, regulations, and any licence conditions imposed by the Commission. A person designated as a DO under section 37 of the NSCA is considered qualified to make decisions related to licensing and compliance, on behalf of the Commission.

All activities in Canada involving the development, production and use of nuclear energy and the production, possession, use, and import and export of nuclear substances, prescribed equipment and radiation devices, and prescribed information may only be carried out under an authorization (i.e., licence) granted by the Commission, or a DO. The NSCA and regulations made under the NSCA include regulatory requirements that must be met by all licensees.

Under the NSCA, the CNSC has the authority to verify licensee compliance with all regulatory requirements. This is done by CNSC inspectors whose powers are outlined in paragraphs 30 to 35 of the NSCA. The CNSC has a variety of enforcement tools to bring licensees back into compliance with the NSCA and associated regulations, such as the notices of non-compliance, issuance of orders or administrative monetary penalties.

The CNSC receives its funding primarily through fees paid by applicants and licensees for regulatory activities. The budget is also supplemented by parliamentary appropriations for special projects and other government funded initiatives. The CNSC can, in accordance with its Cost Recovery Fees Regulations, recover costs associated with some of its regulatory activities under the NSCA. Since April 1, 2021, the CNSC is subject to requirements from the Service Fees Act, whereby related costs are indexed annually and a portion of the fees must be remitted when CNSC service standards are not met. Hospitals, public institutions such as schools, and not-for-profit institutions that receive funds from the government (federal, provincial, municipal) are exempt from licensing fees.

A.3 National and international coordination

The CNSC has powers under paragraph 21(1) of the NSCA to enter into cooperative arrangements with domestic and international authorities in order to attain the objectives of the CNSC. With respect to national coordination related to the safety and security of radioactive sources, the CNSC coordinates and cooperates with domestic agencies on relevant areas of concern, such as the transport of dangerous goods, border controls, radioactive waste management and emergency planning and preparedness. For example, Global Affairs Canada (GAC) and the CNSC have a Memorandum of Understanding (MOU) that outlines key areas for GAC and CNSC collaboration. In particular, the MOU allows for GAC to fund CNSC staff in support of the Code of Conduct to attend meetings and events internationally, where they provide in-kind support for trainings and capacity building activities. During this reporting period, GAC supported CNSC staff participation in 5 IAEA consultancy meetings and 1 technical meeting to review and revise top-tier Nuclear Security Series documents at the Fundamentals and Recommendations levels, an Open-Ended Meeting of Technical and Legal Experts for Sharing Information of States’ Implementation of the Guidance on the Import and Export of Radioactive Sources, 3 meetings of the IAEA’s Nuclear Security Guidance Committee, 3 INFCIRC 908 Steering Committee and Working Group meetings, and the 4th International Conference on Nuclear Security, among others.

Through the Federal Nuclear Emergency Plan, the CNSC contributes to the technical assessment group to manage the consequences involving a significant radiological hazard. To prepare for nuclear or radiological emergencies, the CNSC collaborates with other federal, provincial, and municipal/regional government organizations through various emergency management committees, joint-exercises, and sharing-of-information.

Internationally, the CNSC establishes and maintains cooperation arrangements with international counterparts to share information and best practices, with a view to further enhancing nuclear safety and security in Canada and abroad. Currently, the CNSC has MOUs with 30 counterpart authorities in 27 countries. These provide a framework and instrument for cooperation and information exchange, in the event of an incident with potential transboundary effects, and include arrangements on the import and export of radioactive sources.

Further, the CNSC submits incidents on behalf of Canada to the IAEA’s Incident and Trafficking Database (ITDB). The ITDB is the IAEA’s information system on incidents of illicit trafficking and other unauthorized activities and events involving nuclear and other radioactive material outside of regulatory control. Canada is one of the most active contributors to the ITDB and encourages other Member States to contribute. The CNSC has trained staff to report incidents in a timely manner.

Key international cooperation initiatives

Canada is one of the world’s leading donors to the IAEA’s Nuclear Security Fund, Peaceful Uses Fund and other extra-budgetary programs. Several of Canada’s voluntary contributions directly support projects that strengthen the implementation of the Code. During the 2023–25 reporting period, GAC made voluntary contributions of over $49.4 million through its Weapons Threat Reduction Program to projects that achieved the following:

  • provided financial support to convene Code of Conduct meetings, promote guidance documents and self-assessment tools, and train National Points of Contact to coordinate and collaborate on implementation of the Code
  • financial support to conduct expert missions and regional workshops to promote and build capacity to implement the Code and its Guidance
  • financial support for establishing or updating national registers of radioactive sources and engaging senior and technical stakeholders to promote making a political commitment to the implementation of the Code and its Guidance
  • implemented Regulatory Infrastructure Development Program to provide comprehensive assistance to strengthen both nuclear security and radiation safety in 86 countries in Africa, the Indo-Pacific, and Latin America and the Caribbean
  • strengthened the security of disused sealed radioactive sources (DSRS) by removing 27 DSRS from six Latin America and Caribbean countries and, providing comprehensive assistance for 34 countries in Africa, Central Asia, Eastern Europe, the Indo-Pacific, and Latin America and the Caribbean to sustainably manage their DSRS inventories over their entire lifespan

In November 2024, CNSC, with Canadian Nuclear Laboratories (CNL), hosted the IAEA International Low Level Waste Disposal Network (DISPONET). The purpose of the event was to facilitate the exchange of information and foster discussions with respect to recent experiences, good practices and lessons learned in the disposal of low-level waste including low activity disused radioactive sources. The meeting focused on site characterization, and experiences gained in working with Indigenous Nations and local communities in siting waste disposal facilities when preparing for and conducting site characterization. The participants had the opportunity to visit Canadian facilities at Chalk River and Port Hope.

Key national cooperation initiatives

The CNSC has undertaken deliberate steps to improve regulatory efficiency across the nuclear sector, including activities that support the safe and secure management of radioactive sources. Strengthened collaboration with industry and partners has focused on identifying and addressing opportunities to improve regulatory efficiency without compromising safety or security. The CNSC has initiated industry engagement meetings to prioritize issues based on safety significance, review and streamline reporting and licensing guidance, and leverage data, experience, and international best practices to reduce duplication where appropriate. The CNSC has also modernized how it operates by investing in digital tools, reassessing internal processes and engaging with federal partners.

Meaningful Indigenous engagement has informed and supported these national efforts. The CNSC has engaged Indigenous Nations and communities on regulatory improvements and efficiency initiatives through ongoing consultation and dialogue, ensuring transparency, fairness, and respect for rights and interests. In 2025, the CNSC undertook a national Indigenous listening tour, meeting with Indigenous Nations, communities, and organizations across Canada to gather feedback that will guide improvements to consultation practices, inform implementation of the United Nations Declaration on the Rights of Indigenous Peoples Act and the principles of free, prior and informed consent, and strengthen trust in the CNSC’s regulatory framework.

B. Facilities and services available to the persons authorized to manage radioactive sources

The CNSC already has robust and comprehensive regulatory programs to oversee the control of radioactive sources. In the interest of continuous improvement, the CNSC has initiated the following enhancements to its regulatory oversight programs during the reporting period:

  • The CNSC carries out stakeholder engagement and outreach activities to facilitate communication between the CNSC and the nuclear substance licensees and other stakeholders on licensed activities and regulatory expectations. Outreach activities included emails to targeted groups of licensees, meetings with associations or working groups, presentations at industry conferences, and the publishing of articles in industry publications.
  • Regular circulation of DNSR Digest, a monthly email containing short articles of interest to licensees. Articles during this reporting period have focused on reinforcing regulatory expectations related to compliance and reporting obligations, including the timely submission and appropriate use of annual compliance reports and prompt event notification requirements under REGDOC-3.1.3, Reporting Requirements for Waste Nuclear Substance Licensees, Class II Nuclear Facilities and Users of Prescribed Equipment, Nuclear Substances and Radiation Devices. The digests also emphasized preparedness for emergencies such as evacuations, highlighted trends and lessons learned from reportable events to support a strong safety culture, and reiterated security requirements for nuclear substances and prescribed information, including personnel trustworthiness and reliability verification, physical and administrative security measures, and good practices to enhance nuclear and cyber security.

C. Training of staff in the regulatory body, law enforcement agencies and emergency service organizations

The CNSC maintains a comprehensive approach to training and professional development to ensure that all staff possess the competencies required to deliver the Commission’s mandate. Training opportunities are designed to support technical expertise, regulatory consistency, organizational effectiveness, and continuous improvement across the CNSC. Mandatory and role-specific training is provided to staff involved in regulatory oversight, policy development, security, safeguards, and emergency preparedness, supported by ongoing learning, refresher training, and access to internal and external professional development opportunities. In addition, CNSC staff benefit from participation in employee-led networks, including the Women in Regulatory Enforcement network, the Black Employee Network, the Indigenous Network, and the Pride Network, which contribute to professional growth, inclusion, and organizational resilience.

Inspector-specific training is delivered through the CNSC’s Inspector Training and Qualification Program (ITQP), which ensures that designated inspectors are trained and qualified to carry out their authorized duties. The ITQP includes mandatory core training, service-line-specific training, and structured on-the-job training, with qualifications maintained through refresher training on a 5-year cycle. As part of this program, inspectors receive specialized training relevant to radioactive sources, including source recovery and contamination control for events involving material outside of regulatory control.

Externally, the CNSC continues to provide training to law enforcement and emergency services organizations (first responders) enabling them to address radiological events.

Since 2016, the CNSC, in partnership with federal law enforcement and other federal partners, has developed or supported the delivery of a range of exercises involving investigations into malicious acts involving radioactive sources. These exercises have covered the full scope of an investigation, from crime scene management through forensics, attribution and prosecution.

Since 2024, the CNSC has conducted in-person outreach with local and provincial law enforcement agencies to discuss the presence of radioactive sources within their jurisdictions, as well as the security requirements that licensees must meet, which involve coordination and communication with these agencies.

D. Establishment and maintenance of a national register of radioactive sources

In 2006, the CNSC implemented the Sealed Source Tracking System (SSTS) and the National Sealed Source Registry (NSSR) as components of its efforts in implementing the Code. The CNSC was the first nuclear regulator among the G7 countries to implement a national registry of high-risk sealed sources (Category 1 and 2 sealed sources) and track inventory using a Web-based tracking system. The SSTS is a secure Web-based system that keeps track of inventories of high-risk radioactive sealed sources by allowing licensees to conduct online reporting of source creation, transfer, receipt, import and export, and source exchanges in radiation devices. The information contained in the NSSR is as current as the reporting timeframes required by the licence (e.g., reporting within 2 days of receipt, 24 hours in advance of a domestic transfer and 7 days in advance of an export). The sources are tracked in the NSSR following their manufacturing or importation into Canada. Data related to exported sources, such as their serial number, activity and reference date as well as details related to the export transaction remains available in the NSSR.

The NSSR, which is populated by the SSTS, enables the CNSC to maintain an accurate and secure inventory of Category 1 and 2 sealed sources in Canada. For sealed sources used in high-risk activities such as industrial radiography, licensees are required to report transfer of all sources regardless of their category. Licensees are obligated to submit their inventory for all of their sources via their annual compliance reports. The CNSC consolidates these inventories into a searchable file.

By the end of December 2025, the NSSR contained information on 202,838 radioactive sealed sources of all categories in Canada tracked by the SSTS. This represented an increase of 23.5% over the number of sealed sources in the NSSR at the end of December 2022. The increase has been steady, between 6.2 and 9.4% year over year, for the 3 years covered by this paper. At the end of December 2025, the NSSR contained information on 5,863 Category 1 sources, 89,376 Category 2 sources and 99,448 Category 3 sources. In 2025, the SSTS registered 66,188 individual source transactions of all types. Of these, 99% (65,462) of the transactions were done via the Web interface. Since 2014, each year, over 90% of the source transactions were done via the Web interface, demonstrating successful adoption of the system by Canadian licensees. The remaining transactions were conducted by fax and email and processed by a CNSC staff member directly in the NSSR.

Achievements and planned improvements

As part of efforts related to continuous improvement, the CNSC initiated an improvement project for the SSTS and the NSSR in 2018. This project was subsequently incorporated into the CNSC’s Digital Program, aimed at modernizing the full scope of the CNSC’s systems. Under this Digital Program, the CNSC is currently focused on upgrading its fundamental information technology infrastructure. A subsequent phase of the strategy will include the delivery of a new information management system and the replacement of legacy applications, including the national registry and source tracking system, with modern, composable applications.

Compliance verification

To gauge the effectiveness of the SSTS and verify the accuracy of the data in the system, CNSC inspectors physically cross-reference SSTS data against licensees’ actual inventory of sealed sources. Routine CNSC compliance inspections include verification of sealed source tracking information. Between January 2023 and December 2025, CNSC staff conducted 240 inspections related to the SSTS requirements. The inspections found a high degree of compliance, with 229 (or 95%) of these inspections confirming that licensees were following CNSC requirements. Of the remaining 11 inspections (5%), there were items of non-compliance with regulatory requirements related to sealed source tracking. Examples of non-compliance included licensees failing to provide notification of a source movement within the required timeframe; none of the non-compliances was safety significant. The CNSC ensured that all of these instances of non-compliance were adequately addressed by licensees and corrections were made to the NSSR, if required.

E. National strategies for gaining or regaining control over orphan sources

The Canadian regulatory framework holds licensees responsible for the recovery and safety of lost, stolen and found radioactive sources. In these instances, the licensee is responsible for notifying the CNSC immediately, as well as relevant police authorities, and for conducting a thorough search. When a radioactive source is deemed to be orphaned, the CNSC can and does intervene to identify the licensee owner. For cases where this identification cannot be achieved, the CNSC has a procedure on actions to take and can allocate financial and human resources to ensure that the radioactive source is brought back under regulatory control. Expenses incurred through this activity may be recovered under the CNSC’s financial guarantee program via an insurance policy claim (more details in section F).

To ensure licensee compliance with respect to maintaining control of radioactive sources, CNSC inspectors regularly inspect licensees in possession of Category 1, 2 (as described in Section D above), as well as Category 3 or 4 radioactive sources.

Canada continues to promote awareness among industry, health professionals, the public, and government bodies of the safety and security hazards associated with orphan sources. The CNSC encourages bodies and persons likely to encounter orphan sources through their operations (such as scrap metal recyclers and customs posts) to implement appropriate monitoring programs to detect such sources.

Publication of reports on the safety performance of licensees

The CNSC has published the Regulatory Oversight Report on the Use of Nuclear Substances in Canada annually since 2008 and the Regulatory Oversight Report – Uranium and Nuclear Substance Processing Facilities annually since 2013. Going forward, the CNSC intends to publish this information using an online dashboard accessible on the CNSC web site. This information provides an overview of the safety performance of CNSC licensees with respect to the production of radioactive sources and their use in medical, industrial and commercial applications, as well as for academic and research purposes.

In addition, since 2006, the CNSC has been publishing and will continue to publish annual operational data contained in Canada’s National Sealed Source Registry in the National Sealed Source Registry and Sealed Source Tracking System Report and on the Open Government Portal. The CNSC also maintains a continuously updated report on lost or stolen sealed sources and radiation devices on its web site that summarizes the reports of lost, stolen and found sealed sources and radiation devices in Canada.

F. Implementation of disused radioactive source recommendations of the Code of Conduct and of the Guidance on the Management of Disused Radioactive Sources

Regulatory framework for radioactive sources at end of lifecycle

In September 2018, Canada made a political commitment to the Guidance on the Management of Disused Radioactive Sources, a supplementary guidance to the Code. The CNSC’s regulatory framework does not currently define disused radioactive sources as a separate regulatory category. Instead, the CNSC imposes stringent requirements on all radioactive sources throughout their lifecycle.

In March 2023, the Minister of Energy and Natural Resources released the modernized Policy for Radioactive Waste and Decommissioning for Canada, which ensures the safe management of radioactive waste, reflects the values and principles of Canadians, and continues to align with international standards and best practices.

In July 2023, the CNSC published its Policy and Strategy on Meeting the IAEA Guidance on the Management of Disused Radioactive Sources. In October 2025, CNSC staff participated virtually in the Technical Meeting on the Reuse and Recycling of Disused Sealed Radioactive Sources (DSRS). The meeting focused on presentations from various Member States on their national experiences pertaining to the reuse of DSRS. The meeting concluded with discussion on the finalization of the IAEA’s TECDOC titled Reuse and Recycling of Disused Sealed Radioactive Sources: Approaches and Practical Experiences, which was begun in 2022. Canada is actively working on revising its section of the draft document.

In December 2025, CNSC staff also participated virtually in the Technical Meeting on the Alternative Technology to Radioactive Materials and their Impact of the Management of DSRS.

In 2025, Canada completed a questionnaire regarding the DSRS Management Indicators. This questionnaire aids the IAEA and supports other Member States in developing and maintaining a DSRS management system.

Long-term management of radioactive sources in Canada

A radioactive source may only be transferred in accordance with the conditions of a licence issued by the CNSC. For long-term management, radioactive sources may be returned to the manufacturer in Canada or to their country of origin. In Canada, certain source manufacturers recycle radioactive sources at the end of their useful life by either reusing decayed radioactive sources for other applications, re-encapsulating them or reprocessing them for other useful applications.

When declared as radioactive waste, radioactive sources may also be sent to a licensed radioactive waste management facility or transferred to a person licensed by the CNSC to possess the radioactive sources. If a radioactive source has decayed below its exemption quantity or its clearance levels (as identified in schedule 1 and schedule 2 of the Nuclear Substances and Radiation Devices Regulations (NSRDR), it may also be released from CNSC regulatory control, pursuant to subsection 5.1 of the NSRDR. Even though the radioactive sources may no longer be under CNSC regulatory control, persons possessing them must still follow applicable federal, territorial, provincial, and/or municipal regulations.

In 2023, the Nuclear Waste Management Organization submitted the Integrated Strategy for Radioactive Waste to the Minister of Energy and Natural Resources. This strategy outlines a plan for the long-term management of all of Canada’s radioactive wastes, particularly where disposal plans were not in place, and it was developed in collaboration with waste owners and through engagement with the public and Indigenous peoples across Canada. Later that year, on October 5, the Minister of Energy and Natural Resources released a public statement accepting the strategy’s recommendations.

Financial guarantee program for users of radioactive sources and radiation devices

In 2015, the CNSC established a financial guarantee program for users of radioactive sources and radiation devices. The CNSC has implemented an insurance program through contract with a private institution. Under the program, the CNSC is the sole insured party and licensees pay an annual premium, which is a variable percentage of their total liability (up to a maximum liability of $1 million) and revised on an annual basis. Licensees that choose not to participate or are excluded from the program are required to establish an alternate financial guarantee that is acceptable to the Commission. The establishment of this financial guarantee regime ensures adequate funds will be available for the safe termination of licensed activities in the event of licensee default. REGDOC-3.3.1, Financial Guarantees for Decommissioning of Nuclear Facilities and Termination of Licensed Activities provides guidance on the financial guarantee program, which supports ongoing regulatory control of radioactive sources. The financial guarantee program does not absolve the licensee of its obligations for safe termination of licensed activities. The CNSC is actively participating in recent initiatives by the IAEA to develop guidance on financial provisions associated with the management of disused radioactive sources.

In 2025, an Audit of Financial Guarantees was conducted as part of the CNSC’s routine Risk-Based Audit Program. The audit highlighted a need to reevaluate the financial guarantee program maximum liabilities for certain licensees. As a result, the CNSC is currently working with insurance providers to ensure that the appropriate coverage is being applied and is also developing a tool to trigger further assessment when the maximum liability is no longer sufficient.

Records

Paragraph 36(1)(c) of the NSRDR requires every licensee to keep a record of any transfer, receipt, disposal or abandonment of a nuclear substance.

Radioactive sources in the international community

Re-entry into Canada of previously exported radioactive sources is permitted either by an import licence (with respect to controlled nuclear substances) or in accordance with a general import authorization licence issued by the CNSC. For Category 1 radioactive sources, the exporting state authority is expected to seek prior consent from the CNSC’s point of contact prior to authorizing the export, in accordance with the Guidance on the Import and Export of Radioactive Sources.

G. Experience with arrangements for implementing the import and export provisions of the Code and the Guidance on the Import and Export of Radioactive Sources

The export of Category 1 and 2 radioactive sources as identified in table 1 of annex 1 of the Code requires a risk-informed, transaction-specific authorization issued pursuant to the NSCA. Additional requirements for radioactive sources transiting through Canada are prescribed by the Packaging and Transport of Nuclear Substances Regulations, 2015.

By implementing import and export control measures as outlined in the Code and Guidance, the CNSC enhances national and international safety and security. These measures ensure that only authorized persons can receive Category 1 and 2 radioactive sources. The CNSC’s import and export control program is consistent with the Code and Guidance and aims to:

  • achieve a high level of safety and security regarding Category 1 and 2 radioactive sources
  • reduce the likelihood of accidental harmful exposure to Category 1 and 2 radioactive sources or the malicious use of such radioactive sources intended to harm individuals, society and the environment
  • mitigate or minimize the radiological consequences of any accident or malicious act involving Category 1 and 2 radioactive sources

The CNSC import and export control program remains fully consistent with the provisions of the Code and Guidance. To outline expectations related to the import and export of Category 1 and 2 radioactive sources and to assist exporters applying for export licences, the CNSC published REGDOC-2.13.2, Import and Export, Version 2 in April 2018. In 2025, the CNSC’s Nuclear Non-Proliferation Import and Export Control Regulations were updated and the CNSC began the revision to this regulatory guide to add further clarity to Canadian importers and exporters. The updated REGDOC-2.13.2, Import and Export, Version 3 is expected to be presented to the Commission in late 2026.

Since the publication of Canada’s 2023 National Report, the CNSC has issued 415 export licences, which authorized the export of a total 4.7 million TBq of such radioactive sources to 51 countries.

Through interaction with some of these States during licensing assessments and authorizations, the CNSC has observed that the level of implementation of the Code and Guidance continues to be uneven among States and, in some instances, appears inconsistent with provisions of the Code and Guidance.

Importing State end-of-life management strategy

In support of efforts to ensure continuous control of radioactive sources throughout their lifecycle, the CNSC examines the importing State’s long-term strategy and end-of-life management for radioactive sources as part of the overall State assessment prior to authorizing exports. Obtaining this information remains challenging for States that do not have a fully mature regulatory framework. Radioactive sources exported from Canada may be returned to Canada under a contractual arrangement between the end-user and source supplier, provided that the source supplier is authorized to import, receive, possess and store the radioactive source. Canadian-origin and some foreign-origin radioactive sources return to Canada with the intent of reuse or recycle, thus assisting many States in their end-of-life management strategy.

Import consent – Export from Canada

The CNSC requests import consent from the Importing State Authority for the export of all Category 1 radioactive sources from Canada, regardless of the Importing State’s commitment to the Code and Guidance. For States that have made a commitment to the Code and Guidance, CNSC asks that the response to the request be provided by the importing State authority within 10 business days. To this effect, the CNSC has established a service standard for the processing of applications for export licences of 30 business days.

Where no response is received from the importing State within the specified timelines, the CNSC will first verify with the IAEA if the national point of contact information is accurate. If it is, and there is no justification for the lack of response from the importing State, the CNSC will inform the importing State that it intends to authorize the export when all other considerations are met. This approach provides a final opportunity for the importing State to raise any concerns, while avoiding undue delays.

Point of contact

If an importing State has not provided the IAEA with a point of contact or has not maintained up-to-date point of contact information, identifying an appropriate regulatory authority in the importing State can be a challenge. The CNSC continues to support IAEA initiatives such as training the points of contact to clarify their roles and responsibilities under the Code and Guidance, as well as promoting better communication between Member States with regards to import and export of Category 1 and 2 radioactive sources.

The CNSC continues to encourage points of contact to add or update their information on the IAEA’s list of points of contact, including the use of a generic or functional email address, to help ensure continuity of communication and reduce the risk of delays due to staff turnover or unavailable contacts.

Import consent – Import into Canada

The use of bilateral administrative arrangements defining communication protocols has improved the import consent process, and since the 2023 IAEA Code of Conduct Review Meeting, the CNSC has continued to observe a modest increase in the number of import consent requests received. This increase can be attributed in part to communication with counterparts in other exporting States, IAEA regional workshops on implementation of the Code and Guidance, established arrangements between the CNSC and foreign regulators and also from increases in States’ commitments to the Code and Guidance. However, there remain ongoing implementation challenges with States that have made a political commitment to the Code and Guidance, but who do not respond to import consent requests, who fail to request import consent when exporting Category 1 radioactive sources, or do not provide advance prior shipment notifications.

Where import authorization has not been obtained prior to export or no prior notification has been received, as appropriate, shipments may be unable to proceed as planned, may be refused entry into Canada, or may be returned to the exporting State.

Assessment of State regulatory framework

In accordance with the Code and Guidance and also to ensure that Canada meets its international commitments, the CNSC reviews the importing State’s regulatory framework as part of its export application assessment. The CNSC relies on information provided by the importing State, open-source information, the Guidance questionnaire responses and other information gathering channels to assess the regulatory framework. As stated in the 2023 National Report, the level of responses to the revised Guidance questionnaire continues to remain low in comparison to the number of States that have provided political commitment to the Guidance, which lessens its overall impact. The CNSC encourages States to complete the Questionnaire and agree to make it available to other States.

Prior shipment notifications

All export licences issued by the CNSC for the export of Category 1 and 2 radioactive sources require the licensee to issue prior shipment notifications to the Importing State Authority and to the CNSC, a standard advanced notification period of 7 days. The CNSC will consider a reduced prior shipment notification when the standard 7-day period may impact the export shipment and will notify the importing State accordingly.

Reciprocally, the CNSC expects States committed to the Code and Guidance to submit prior shipment notifications for Category 1 and 2 radioactive sources being exported to Canada. As noted above, not consistently receiving prior shipment notifications for the import of radioactive sources into Canada remains an issue of concern for the CNSC, who would also seek the opportunity to grant import consent for the import of Category 1 radioactive sources into Canada.

Post-shipment verification

The licensee is required to submit post-shipment verification notification to the CNSC, confirming that the export has occurred; i.e., that the radioactive sources have left Canada.

Confirmation of receipt of imported radioactive sources

No provision exists under the Code and Guidance for the importing authority to confirm receipt of the radioactive source by the intended end-user to the exporting state authority. On occasion, the CNSC has requested or provided information related to the receipt of radioactive sources. Although no instances of loss or diversion of Canadian-origin radioactive sources have been identified, establishment of a procedure to confirm receipt of exported radioactive sources can enhance the safety and security of such radioactive sources by providing assurances that the intended end-user is in receipt of the exported radioactive sources.

Bilateral arrangements

A key element of the CNSC’s regulatory control program for the import and export of radioactive sources involves the establishment of bilateral administrative arrangements (AAs), pursuant to section 21(1) of the NSCA, with regulatory authorities in countries with which Canada has substantial trade in radioactive sources (Category 1 and 2) and with countries that also share Canada’s commitments to effective international controls on transfers of radioactive sources. The establishment of bilateral AAs helps to harmonize and streamline the import and export processes. Canada continues to seek opportunities to negotiate bilateral AAs with other States.

The practice, which is consistent with paragraph 20(n) of the Code and paragraphs 5, 6, 9, and 12 of the Guidance, is highly regarded internationally, as it assists other States in implementation of the Code and Guidance and forms part of Canada’s international obligations related to security cooperation. As of December 31, 2025, the CNSC has 12 bilateral AAs with other countries.

H. Additional topics relevant to the implementation of the Code of Conduct and the Guidance

As a regulator, the CNSC recognizes the need to be mindful of, and manage regulatory burden, to expedite reviews, to maintain a competent and talented workforce, and to innovate and leverage new techniques, approaches and technologies to find even greater efficiencies.

The CNSC’s efforts are informed by ongoing consultation and feedback received by engaging with Indigenous Nations and communities, non-governmental organizations and the industry it regulates. Recent work has focused on ensuring readiness for new entrants and technologies – clarifying expectations without increasing burden so that they have a clear understanding of CNSC regulatory requirements will ensure that all are working towards the same goals. This includes reducing what is perceived as regulatory burden by identifying efficiencies in our processes. To this end, the CNSC has initiated industry engagement meetings aimed at identifying, prioritizing and addressing opportunities to improve our regulatory framework while ensuring safety and security.

The CNSC remains committed to modernizing how it works – it is essential that the supporting infrastructure (i.e., digital tools, capacity, etc.) enables and accelerates the changes it aims to deliver.

Conclusion

In alignment with Canada’s longstanding political commitments to the IAEA, Canada continues to maintain a comprehensive, risk informed and effective framework for the safety and security of radioactive sources throughout their lifecycle. During the 2023–25 reporting period, Canada strengthened its regulatory system through legislative and regulatory modernization, enhanced tracking and control mechanisms and continued improvements in inspection, compliance verification, governance, and regulatory efficiency. Canada also expanded engagement with Indigenous Nations, stakeholders and international partners. Independent international peer review, including the IRRS follow-up mission, confirmed the robustness of Canada’s framework and its commitment to continuous improvement. Through sustained national coordination, significant international cooperation, and ongoing modernization initiatives, Canada continues to contribute to global efforts to maintain effective control of radioactive sources, strengthen safety and security arrangements, and ensure regulatory programs remain adaptive, transparent and aligned with international standards and guidance.

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