Securing · Metric

Foreign investment screening in international context

Economic security begins at the border of ownership: who is allowed to buy control of the assets a country considers strategic — its mines, ports, telecoms, data, and advanced technology. Canada screens such deals under the Investment Canada Act, and in the past four years it has gone from a light-touch regime to one with real teeth — ordering Chinese state-linked investors out of critical-mineral juniors and, in 2024, finally modernising the law. The catch is that it did so years after its closest allies, and on a still-short track record.

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.

Chinese firms ordered to divest, Nov 2022
3
State-linked investors unwound from Canadian lithium/critical-mineral juniors; SOE critical-minerals deals now approved "only on an exceptional basis."
Extended national-security reviews, 2024–25
30
Up from 11 in 2020–21 — the regime has clearly activated, concentrated on China, critical minerals, and technology.
Year Canada modernised the Act
2024
Bill C-34 added pre-close filing for prescribed sectors, bigger penalties, and interim-condition powers — after the US (2018), Australia (2020–21), and UK (2021).

The regime has activated

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.

Investments subject to extended national-security review, by fiscal year (Canada)
Source: ISED, Investment Canada Act Annual Reports. Figures are investments subject to an extended national-security review (s.25.3): 2020–21 = 11; 2021–22 = 12; 2022–23 = 32 (record); 2023–24 = 26; 2024–25 = 30. Earlier years are reported as "s.25.3 orders"; 2022–23 onward as "extended reviews" — essentially the same gateway, with a minor labelling change noted in the workbook.

How Canada's regime compares

Raw review counts are not comparable across countries — each regime has different 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 — but it arrived last.

Foreign-investment security screening: Five Eyes regimes compared
CountryRegimeModernisedMandatory pre-close filing in strategic sectorsRecent enforcement
🇨🇦 CanadaInvestment Canada Act2024 (Bill C-34)Yes — for prescribed sectors, from 2024–252022 critical-mineral divestitures (3 firms)
🇺🇸 United StatesCFIUS / FIRRMA2018Yes — certain covered transactions~209 notices/yr; multiple unwound deals
🇬🇧 United KingdomNational Security & Investment Act2021Yes — mandatory in 17 sectors56 call-in notices (2024–25)
🇦🇺 AustraliaFIRB / Foreign Acquisitions Act2020–21Yes — above value/sector thresholdsRoutine blocks & divestitures incl. critical minerals
Sources: ISED (Canada); US Treasury CFIUS Annual Report 2024; UK NSIA Annual Report 2024–25; Australian Treasury / FIRB. "Recent enforcement" figures use each regime's own latest reporting and are illustrative — scopes and definitions differ and the counts are not directly comparable.
Why "modernised last" matters. The US hardened CFIUS in 2018 (FIRRMA), Australia overhauled FIRB in 2020–21, and the UK stood up the NSIA in 2021 — each in response to the same concern about strategic acquisitions by state-linked buyers. Canada's equivalent overhaul (Bill C-34) only received royal assent in 2024. For roughly half a decade Canada screened strategic deals with weaker tools than its partners — a gap that the flagship 2022 minerals action partly, but not fully, offsets.

Findings

Finding 1

Canada has acted on the flagship case

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 — the strongest evidence in Canada's favour.

Finding 2

National-security scrutiny has stepped up

Extended national-security reviews rose from ~11 (2020–21) to a record 32 (2022–23) and have held near 30 since — a structural increase in scrutiny, concentrated on state-linked acquirers in critical minerals, technology, and data.

Finding 3

But Canada modernised last among the Five Eyes

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), and UK (2021). For years Canada guarded strategic assets with weaker tools than its allies.

Finding 4

The track record is short and contested

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.

The verdict is Watch — an improving regime with a thin record. Canada has the powers it needs and has shown, in the critical-minerals divestitures, that it will use them. But it built those powers late, applies them with wide discretion, and has not yet accumulated the consistent track record that would let it be called a settled strength. Economic security is now firmly on the agenda; whether the gate is minded reliably, deal after deal, is the test of the next few years.

Sources & methodology

Primary sources
Methodology notes
  1. 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.
  2. 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.
  3. 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.
  4. Verdict. "Watch" reflects a materially strengthened framework (2022 action, 2024 C-34) set against a late modernisation and a short, contested enforcement record — not a judgement that any particular deal was decided wrongly.
  5. Companion workbook. The editable review-count series and regime-comparison table live in Securing_Investment-Screening_Data.xlsx.
Page last reviewed June 2026 · Data current to 2024–25 — the latest ISED Investment Canada Act annual report