- Critical mineral reserves & production — what Canada holds in the ground and how much it actually produces.
- Mineral exploration investment — the capital flowing into the search for new deposits.
- Mine permitting & development times — how long it takes to turn a discovery into a producing mine.
- Critical mineral refining capacity — the refining and processing chokepoint between ore and finished material.
- Energy capital investment — capital spending across the energy and resource sector.
This metric was deliberately scoped wider than minerals. The threat that screening guards against, a strategic rival acquiring control of critical infrastructure or technology, is not specific to one sector, so the right benchmark is the strength of the screening regime itself, with critical minerals as the flagship case rather than the whole story. On that basis Canada has improved markedly. The open question, and the reason this lands as a Watch rather than a clear strength, is whether a regime that modernised last among the Five Eyes will be used consistently enough to match its new powers.
For most of its history the Act's national-security power was used sparingly. That changed sharply after 2021: the number of investments pushed into an extended national-security review jumped from around a dozen a year to a peak of 32 in 2022–23, the year of the critical-minerals divestitures, and has stayed near 30 since. The scrutiny is concentrated on state-linked acquirers (overwhelmingly Chinese) in critical minerals, advanced technology, and data.
Raw review counts are not comparable across countries. Each regime has its own thresholds, scope, and triggers (Australia's FIRB also screens real estate; the UK's NSIA mandates filing in 17 sectors; CFIUS targets fewer, higher-value deals). The more honest benchmark is the design of the regime. On structure, Canada's 2024 reforms brought it broadly into line with its Five Eyes partners. It arrived last.
| Country | Regime | Modernised | Mandatory pre-close filing in strategic sectors | Recent enforcement |
|---|---|---|---|---|
| 🇨🇦 Canada | Investment Canada Act | 2024 (Bill C-34) | Yes — for prescribed sectors, from 2024–25 | 2022 critical-mineral divestitures (3 firms) |
| 🇺🇸 United States | CFIUS / FIRRMA | 2018 | Yes — certain covered transactions | 207 notices and 140 declarations (2025); mitigation required in 25 transactions |
| 🇬🇧 United Kingdom | National Security & Investment Act | 2021 | Yes — mandatory in 17 sectors | 60 call-in notices (2025–26) |
| 🇦🇺 Australia | FIRB / Foreign Acquisitions Act | 2020–21 | Yes — above value/sector thresholds | Routine blocks & divestitures incl. critical minerals (Northern Minerals disposal orders, 2024 and 2026) |
| 🇳🇿 New Zealand | Overseas Investment Act — national security & public order regime | 2021 | Yes — military or dual-use technology, and critical suppliers to defence and intelligence agencies | No comparable count located |
In November 2022 Canada ordered three Chinese state-linked firms to divest from Canadian lithium and critical-mineral juniors, and set a policy that foreign-SOE critical-minerals deals will be approved "only on an exceptional basis." It is a clear, applied demonstration that the regime can intervene, and the strongest evidence in Canada's favour.
Extended national-security reviews rose from ~11 (2020–21) to a record 32 (2022–23) and have held near 30 since. The increase is structural, concentrated on state-linked acquirers in critical minerals, technology, and data.
Mandatory pre-close filing, larger penalties, and interim-conditions powers arrived only with Bill C-34 in 2024, after the US (2018), Australia (2020–21), the UK (2021), and New Zealand (2021). For years Canada guarded strategic assets with weaker tools than its allies.
Enforcement volume is modest and application is seen as discretionary. Some sensitive deals have been approved, and the regime's consistency is debated. The framework is now broadly peer-level; whether it is wielded reliably is unproven, which is why this is a Watch, not a strength.
Canada's screening regime is now broadly in line with its allies' on design, but it was the last of them to modernise and its enforcement record is short.
- Compared with
- The foreign-investment screening regimes of the other Five Eyes (the United States, the United Kingdom, Australia, and New Zealand), compared on design. Review counts are not comparable across countries.
- Where Canada sits
- Broadly peer-level on design since Bill C-34 (2024), and the last of the five to modernise, after the US (2018), Australia (2020–21), the UK (2021), and New Zealand (2021).
- Which way it is moving
- Up. Extended national-security reviews rose from 11 in 2020–21 to a record 32 in 2022–23, and stood at 30 in 2024–25.
- What the verdict follows
- Position among the Five Eyes on the design of the screening regime, the page's headline measure. On design Canada is broadly peer-level, the middle of the set, although it was last of the five to modernise. The framework has caught up, but whether it is applied consistently is not yet shown on a short, contested record, so Watch.
- Data basis
- ISED, Investment Canada Act Annual Report 2024–25 and prior years; US Treasury, CFIUS Annual Report for calendar year 2025; UK NSIA Annual Report 2025–26; Australian Treasury / FIRB; Land Information New Zealand. Page last reviewed June 2026.
Primary sources
- ISED, Investment Canada Act Annual Report 2024–25 (and prior years) — national-security review counts and filings.
- Government of Canada (Oct/Nov 2022) — divestiture orders against three Chinese firms; SOE critical-minerals policy.
- US Treasury, CFIUS Annual Report for calendar year 2025 (released 7 August 2026); UK NSIA Annual Report 2025–26 (published 20 July 2026); Australian Treasury / FIRB, including the Treasurer's Northern Minerals disposal orders (June 2024 and May 2026) — peer-regime structure and activity.
- Land Information New Zealand, Overseas Investment Office — national security and public order regime (in force 7 June 2021) and the 2025 amendment (in force 6 March 2026).
Methodology notes
- Scope. The metric assesses the strength of Canada's foreign-investment security-screening regime across all strategic sectors (minerals, technology, data, infrastructure), not minerals alone. Critical minerals appear as the flagship enforcement case.
- Cross-country comparability. Review/filing counts are not directly comparable. Regimes differ in thresholds, mandatory scope, and what they capture (e.g., FIRB includes real estate; NSIA mandates 17 sectors; CFIUS covers fewer, larger deals). The comparison table therefore benchmarks design features, and the enforcement-count column is flagged as illustrative only.
- New Zealand. The table dates New Zealand's modernisation to its national security and public order call-in regime, in force from 7 June 2021. A later reform, the Overseas Investment (National Interest Test and Other Matters) Amendment Act 2025, in force from 6 March 2026, streamlined consents and introduced a national interest test. It did not create the security powers, which date from 2021.
- Canada series. The trend uses "investments subject to extended national-security review (s.25.3)"; the label shifts from "s.25.3 orders" (to 2021–22) to "extended reviews" (2022–23 on), the same gateway with a minor reporting-label change.
- Verdict. "Watch" reflects a materially strengthened framework (2022 action, 2024 C-34) set against a late modernisation and a short, contested enforcement record. It is not a judgement that any particular deal was decided wrongly.
- Companion workbook. The editable review-count series and regime-comparison table live in Securing_Investment-Screening_Data.xlsx.
