Bill C-15: Omnibus Risks and Division 5
By Kellie Auld
As Canadian citizens, we should all be asking parliament to review and challenge the serious implications of Bill C-15, the Budget Implementation Act (2024). This bill contains over 50 amendments to unrelated Acts, bundled into one omnibus package. Many of these changes would normally require full debate, consultation, or separate legislation.
This briefing highlights the most serious concerns.
- Status of Bill C-15 (February 2026)Not Passed. Currently before the Senate Standing Committee on National Finance. Still subject to amendment, removal of problematic divisions, or being returned to the House for reconsideration. The bill has not received Royal Assent.
- What Is Buried Inside Bill C-15The Budget Implementation Act contains amendments to more than 50 Acts, including the Income Tax Act, Canada Labour Code, Employment Insurance Act, Immigration and Refugee Protection Act, Criminal Code, Investment Canada Act, FINTRAC / Anti-Money-Laundering regime, environmental and resource-sector laws, Infrastructure Bank & housing programs, health and transportation statutes, and digital-compliance and administrative-state frameworks across multiple departments.These are substantive policy changes, not budgetary items.
- Division 5 — The Most Concerning SectionDivision 5 amends the Department of Employment and Social Development Act to allow a minister to exempt themselves from statutory obligations, exempt unnamed public servants from those same laws, issue exemption orders that override existing Acts, and do so without public reporting, disclosure, or parliamentary review.This effectively allows ministers and delegated officials to neutralize laws internally.
- Why Division 5 Requires Removal or Major AmendmentDivision 5 would replace rule-of-law with rule-by-administrative directive, expand executive power without accountability, undermine Parliamentary oversight, allow departments to force citizens into digital-only systems by exempting themselves from statutory service obligations, and remove transparency from decisions affecting benefits, eligibility, access, and due process.
No budget should contain powers that permit elected officials or unnamed bureaucrats to ignore laws, override statutory protections, or operate without disclosure.
I am asking Canadians to write to their MP’s. State that you respectfully request that the MP advocate for one of the following outcomes:
Option A — Remove Division 5 entirely from Bill C-15.
Option B — Require Division 5 to be introduced as a standalone bill. Option C — Apply strict amendments: mandatory publication of any exemption orders; parliamentary review and approval; prohibitions on delegating exemption power to unnamed officials; strict limits and sunset clauses.
These are the minimum guardrails required in a democratic system. Budget bills should not be used to expand executive power, weaken transparency, or alter dozens of Acts through a single vote.
I urge you, dear reader, to review the structure and implications of Bill C-15 and support measures to remove or amend Division 5.
Please make yourself aware of what is going on in Ottawa – it will affect us all!
Kellie Auld is a retired communications specialist who spent nearly 20 years with the RCMP before becoming an HR consultant and later running a licensed investigations firm. Her legal and investigative background led her to question whether Canada is shifting from a democratic system toward an administrative state.
If you’d like to read more of Kellie’s writings, please visit substack.com/@katrinaroo











