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.
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 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.
| 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 | ~209 notices/yr; multiple unwound deals |
| 🇬🇧 United Kingdom | National Security & Investment Act | 2021 | Yes — mandatory in 17 sectors | 56 call-in notices (2024–25) |
| 🇦🇺 Australia | FIRB / Foreign Acquisitions Act | 2020–21 | Yes — above value/sector thresholds | Routine blocks & divestitures incl. critical minerals |
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.
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.
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.
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.