On 5 March 2025, the Government of Canada updated the Guidelines on the National Security Review of Investments under the Investment Canada Act to better address evolving geopolitical and economic threats. Key changes include:
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Recognition of economic security as a core consideration: Foreign investments will now be assessed not only for traditional security risks but also for their potential to create strategic dependencies, disrupt critical supply chains, or undermine Canadian control over key innovation sectors. Factors such as the size and strategic importance of the Canadian business, its role in the innovation ecosystem, and its impact on critical supply chains will be considered.
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Replacement of Annex A (Sensititve Technology Areas) with the Sensitive Technology List (STL): The STL identifies emerging and dual-use technologies that may be vulnerable to foreign exploitation, ensuring a more targeted and adaptive approach to safeguarding critical technologies.
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Inclusion of specific risk factors: National security assessments will now also consider the proximity of the investment to military or strategic assets, the investor’s ties to foreign governments—particularly those associated with cyberespionage or economic coercion—and risks to data sovereignty and cyber infrastructure.
