Augmentios
POLICY BLUEPRINT · VERSION 1.0 · OCTOBER 26, 2026

A Strategic Blueprint to Cure Canada's Innovation Paralysis in Life Sciences

How Canada Can Keep the Companies, Capital and Returns Its Research Creates

Natalie Yeadon, Founder & CEO, Augmentios · Breaking Innovation Paralysis
Contents

Suggested citation

Yeadon, N. (2026). A Strategic Blueprint to Cure Canada's Innovation Paralysis in Life Sciences: How Canada Can Keep the Companies, Capital and Returns Its Research Creates (Version 1.0) [Report]. Augmentios. Zenodo. https://doi.org/10.5281/zenodo.23621505

DOI and author

DOI: 10.5281/zenodo.23621505 · ORCID: 0009-0002-9502-412X

Licence

© 2026 Natalie Yeadon, Augmentios. Licensed under CC BY-NC-ND 4.0: share with credit, non-commercial use only, no modified versions. This web edition is the same text as the version of record on Zenodo.

Acknowledgements

The author thanks Ewan Affleck, Kyle Briggs, David Durand, Tony Pullen, Nigel Rawson and Walter Robinson for comments on earlier drafts. Reviewers commented in a personal capacity; they do not necessarily endorse the recommendations, and any errors are the author’s.

This blueprint is independent and self-funded. The views expressed are the author’s own. Citing a person, organization or publication does not imply its endorsement of this blueprint.

Executive Summary

Canada excels at funding world-class life sciences research but struggles with commercialization. While our country ranks second in the G7 for higher-education R&D, our business R&D investment sits near the bottom of the G7 at 0.9% of GDP, compared to 2.7% in the United States [Statistics Canada; NSF NCSES]. Over a 15-year period, 21 Canadian life sciences companies were acquired by foreign buyers for over $500 million each, and of the investors who saw returns from the top 20 therapeutic exits, only 23% were Canadian [adMare Institute, 2025]. That is a count of investors, not a share of the money. Further up the chain, of the disclosed limited partners behind the funds that financed those exits, 81% were American and 6% Canadian; these too are counts, from partial disclosure, and directional [adMare Institute, 2025]. The largest exits went abroad: seven of the top 20, each a foreign acquisition of more than US$1 billion (including Chinook by Novartis, Fusion by AstraZeneca and Bellus by GSK), accounted for about 71% of the total value of those exits [adMare Institute, 2025]. This structural gap is driven by a chronic scale-up capital deficit and regulatory and reimbursement bottlenecks that lead to extensive capital and intellectual property (IP) leakage.

To break this cycle, this blueprint delivers a coordinated, eight-reform priority package. It requires no new discovery funding, focusing instead on anchoring capital, matching international tax incentives, and transforming the public healthcare system into an active first customer. The reforms are chosen for leverage and listed in the order a company meets them; their engine is the anchor stage, where Canadian capital keeps companies, and the returns they generate, in Canada.

Beyond the priority package, the Reform Catalogue in Part 3 follows a company through the three valleys of financing: from the lab to a fundable company, through scale-up, and to the anchor stage of listing and staying Canadian-owned, where Canada has lost many of its most valuable life sciences companies.

The Priority Package at a Glance

1. Streamlined Licensing, Venture Philanthropy and IP Retention (Modules 3A.1, 3A.9, 3A.3): Phases in the Simple Agreement for Innovation Licensing (SAIL), an express university licence, from voluntary adoption by Canadian universities, to federal and provincial top-ups for adopters, to a condition of Tri-Agency funding once the data show it works; seeds a national venture philanthropy fund that recycles its returns into the next cohort of spinouts; and attaches incentive-based IP-retention terms, support first and conditions second, to public capital in this package, so Canadian discoveries start, and stay, on Canadian terms.

2. Anchor-Aligned Capital Gains Exemption (Module 3B.1): Introduces a 0% inclusion rate (capped at $15M per business) for long-held small business stock in life sciences and deep tech to compete against the 0% U.S. QSBS rate, with the full benefit for gains realized through a Canadian listing or a sale to a Canadian buyer, and a reduced benefit when the exit is a foreign acquisition.

3. A Late-Stage Life Sciences Growth Window (Module 3C.1): Builds on the October 2026 Venture and Growth Capital Plan, through a life sciences sleeve in its $675 million later and growth stage stream alongside the $200 million VCCI life sciences stream, with new money if needed, so domestic funds can lead $50M-plus growth rounds with fund lives suited to clinical timelines.

4. Tiered SR&ED Credits for Clinical Trials (Module 3E.6): Extends the enhanced 35% SR&ED tax credit, on a refundable basis for Canadian-controlled companies, to clinical trials run at Canadian sites, from Phase I through postmarketing Phase IV, with a basic credit for foreign sponsors' Canadian trials and repayment if credit-funded IP leaves Canada, to reverse Canada's declining share of global trials.

5. Domestic Capital Compact (Modules 3D.3, 3D.2): A voluntary, Tibi-style compact in which pension funds and other institutional investors pledge capital to labelled funds that back Canadian late-stage and listed life sciences companies, with a listed-company sleeve that can take cornerstone positions in Canadian IPOs.

6. Family and Philanthropic Capital Channel (Modules 3C.6, 3C.5): Brings family offices into the compact and the federal fund-of-funds on the same terms as pension funds, revives the capital gains exemption on donated private shares, lets foundations count venture investments toward their disbursement quota, and pilots a capped innovation rollover for estates and business sales.

7. Total Economic Return Procurement Scoring (Module 3F.1): Deploys a 100-point balanced scorecard, adopted through dedicated federal funding for provinces that sign on, evaluating clinical net yield, supply chain resilience, and domestic R&D to shift provincial single-payers away from narrow cost-minimization.

8. Approved-but-Not-Pursued Exit Registry (Module 3G.1): Publishes an annual list of medicines approved in the United States or Europe but never filed in Canada, and requires sponsors whose approved therapies are not submitted for public reimbursement to file a short public reason, chosen from standard categories, with no confidential pricing or commercial strategy disclosed, so the access gap can be seen and fixed.

Implementation at a Glance

Part 4 sets out the rollout in four phases over about five years. The first six months are for steps that need no new legislation: phased licensing adoption, the investor compact, the interim Exit Registry, the outcome review of funded intermediaries and the regulatory readiness rule. From months 6 to 18, the tax measures go into the next federal budget and its Budget Implementation Act, and the new statutes are drafted and introduced. In years 1 to 3, the procurement, co-funding and health data measures start with willing provinces and territories. From year 2, the capital vehicles are deployed and a permanent coordinating authority takes over from the transitional Implementation Task Force. The phases mark when each step starts, not when it is finished: measures that need the provinces and territories, such as procurement scoring and health data, will take longer, and are designed to start with willing jurisdictions rather than wait for all of them.

Preamble

For over a century, Canada has been an exceptionally fertile ground for life sciences discovery. From the Nobel Prize-winning isolation of insulin at the University of Toronto in 1921 to the pioneering of global blockbusters like Visudyne and 3TC, our academic laboratories, clinical research networks, and public health systems have produced discoveries of global significance. Yet, the primary economic and social rewards of this innovation engine have gone elsewhere.

Canada does not have an invention problem; it has a scale conversion problem [BetaKit, 2017]. The Council of Canadian Academies found that Canada's business R&D gap persists within the same sectors, showing that industrial mix does not explain it [Council of Canadian Academies, 2013]. Many Canadian-invented patents do not result in Canadian-owned corporate assets: the share of U.S. patents with a Canadian inventor assigned directly to foreign firms on their date of issue more than doubled over a twenty-year horizon, reaching 45 percent [IRPP, 2019]. Policy is lopsided in the same way: support concentrates on start-ups and early-stage firms, while the missing middle, firms that grow to mid-size and lead a global niche, and the anchors they can become, receives little [Barber and Crelinsten, 2016].

The modern history of Canadian biotechnology is a vicious cycle of capital and intellectual property (IP) leakage [Council of Canadian Innovators, 2026]. We excel at subsidizing the high-risk, early-stage laboratory phase through non-dilutive public grants and specialized tax incentives [EY, 2026]. However, the moment a homegrown firm approaches its critical value inflection point—the transition into multi-centre Phase II and III clinical trials—it encounters a thin domestic capital market [CVCA, 2025; Pharmaceutical and Life Sciences Sector Task Force, 2026]. The federal Pharmaceutical and Life Sciences Sector Task Force described the same gap in its Report to the Ministers of Health and Industry, released in July 2026.

Because Canadian venture funds remain too small to write late-stage cheques without breaching concentration limits, and because our multi-trillion-dollar institutional pension asset managers allocate just ~18% of their public equity portfolios and ~3% of their total assets under management to domestic equities, our most promising firms face a structural disadvantage [Betermier, 2024; New Financial, 2024]. They are financially compelled to scale on foreign venture capital, cede control, and relocate their corporate headquarters to the United States or Europe.

This commercial flight is compounded by a public healthcare apparatus that operates predominantly as a closed buyer to domestic innovation. Legacy procurement systems reward the lowest upfront unit cost rather than system-wide clinical efficiency or domestic economic yield, while a slow, sequential federal-provincial review pipeline delays market entry. Only 48.5% of approved drugs are even submitted for public reimbursement review [Pharmaceutical Technology / GlobalData, 2026]. epiSign, a rare-disease diagnostic platform developed in London, Ontario, was in clinical use abroad for years before Ontario finally made it reimbursable for local patients in late 2025 [TechAlliance, 2025].

Part of the problem is how the system is seen. Health policy puts two different economies in the same box. The distribution economy buys and delivers care: drugs, devices, physicians and hospitals, and it is managed as a cost. The innovation economy creates the biotechnology, medical technology and health technology built on Canadian science, and it adds to GDP per capita, exports and tax revenue. When both are debated as one, every conversation turns to access and price, and the innovation economy gets a fraction of the attention and money. Health and life sciences are not treated as a national strategic and economic priority. This blueprint treats the innovation economy as one. Spending more on distribution has not bought more care. In 2024 Canada spent 11.5% of GDP on health, against an OECD average of 9.4%, yet had 2.7 physicians per 1,000 people against an OECD average of 4.1, and 10.4 MRI units per million people (OECD Health Statistics, 2026). In the Commonwealth Fund's 2023 survey of 10 high-income countries, only 26% of Canadians could get a same- or next-day appointment, the lowest of any country surveyed (Commonwealth Fund, 2024; CIHI, 2024).

The purpose of this policy blueprint is to break this cycle.

The structural interventions detailed in the following pages do not call for more discovery funding. Instead, they apply immediate, coordinated urgency to the execution, capitalization, procurement, and market-access milestones where Canada historically loses what it builds. By realigning our national tax code, mobilizing pension-scale late-stage capital, transforming the public healthcare system into an active first customer, and keeping control of Canadian champions in Canada, this framework builds a path of least resistance for scale.

Our country possesses the raw scientific material, world-class clinical capabilities, and underlying market liquidity required to build independent industrial pillars. This document provides the operational, legislative, and structural architecture to secure their growth.

How to Use This Blueprint

This policy blueprint functions as an integrated legislative and financial strategy. The document is divided into thematic parts that establish the problem, trace its structural origins, and map out isolated, standalone intervention modules:

  1. The Executive Summary & Preamble: Establish the macro data, economic stakes, and narrative logic of the priority reforms.
  2. Part 1: Diagnosis: Traces the empirical baseline of Canada's innovation leakage across corporate and academic life sciences channels.
  3. Part 2: The Priority Package: Outlines the capital flywheel and the interconnected policy levers.
  4. Part 3: The Reform Catalogue: Comprises detailed proposals (Modules 3A.1 to 3H.6) for legislative drafters, organized in eight sections that follow a company from the lab to the patient, including the three valleys of financing. Every module uses the same six fields: Problem, Proposal, Precedent, Evidence, Impact, and Points of Debate, so any module can be lifted into a brief, op-ed, or slide without rewriting.
  5. Part 4: Implementation: Maps out the immediate 90-day phase-in steps and downstream operational horizons.
  6. Part 5: References: Lists the sources cited throughout the text.

Policy officials can isolate single modules in Part 3 to stand up immediate programs, or follow the phased timeline in Part 4 to implement the priority package.

A note on interests: the author is the founder and CEO of Augmentios, a life sciences advisory firm. This blueprint is independent and self-funded; no organization commissioned or paid for it. Some proposals, such as clearer rules for introducers of capital (3C.7), concern fields in which advisory firms like Augmentios may work.

Part 1: Diagnosis

Canada has a scale conversion problem. We excel at funding world-class public research but fail at building independent anchor companies. While Canada ranks second in the G7 for higher-education R&D, our business R&D investment sits near the bottom of the G7 at 0.9% of GDP (compared to 2.7% in the United States).

The data proves this is not a sector-mix issue; it is a structural failure to scale.

The Core Evidence

IndicatorCanada's MetricImpact / Source
Business R&D Intensity~0.9% of GDPLagging significantly behind the U.S. (2.7%). (StatsCan)
Life Sciences VC Share7% of total investmentDespite yielding the highest 10-year gross returns (~20%). (Pharmaceutical and Life Sciences Sector Task Force, 2026)
Foreign Takeovers (>$500M)21 companies over 15 yearsValued at an average of $1.8B each; stripping Canada of anchor firms. (Pharmaceutical and Life Sciences Sector Task Force, 2026)
Domestic Investor ShareOnly 23% of investors were CanadianInvestors seeing returns from the top 20 therapeutic exits since 2013; a count, not a share of value. (adMare Institute, 2025)
Domestic Institutional Ownership0% in top 3 public biotechsXenon, Zymeworks, and AbCellera have no Canadian institutional ownership. (Pharmaceutical and Life Sciences Sector Task Force, 2026)
Pension Asset Allocation~18% of public equity portfoliosDown from 33% in 2013. Domestic equities make up just ~3% of total assets under management (AUM). (Betermier / New Financial)
Innovation Leakage (Macro)58% of U.S. patents with Canadian inventorsPlaced in foreign hands by 2016, up from 45% in 2005 across all tech sectors. (U of T Impact Centre)
Innovation Leakage (At-Issue)More than doubled from 18% to 45%Share of U.S. patents with a Canadian inventor assigned directly to foreign firms on their date of issue. (Gallini & Hollis, IRPP)
Market Entry Pipeline48.5% of approved drugsShare of Health Canada approvals that are submitted for public reimbursement review. (Canada's Drug Agency)
Biotech Capital Growth59% less capitalGenerating 21.4% vs 43.1% annual growth compared to U.S. peers. (C.D. Howe Institute)

Value Created Here, Captured Elsewhere

The pattern of Canada's life sciences sector is not failure; it is leakage.

  1. The Inflection Point: Companies reach critical value thresholds using Canadian infrastructure, clinical expertise, and public tax credits.
  2. The Foreign Pivot: Lacking large domestic growth funds, they scale on foreign venture capital, relocate their IP and executive leadership to the U.S. or Europe, and eventually sell out.
  3. The Premium Buy-Back: A Council of Canadian Innovators (CCI) study found that 28 out of 30 acquired Canadian technology and life sciences firms lost strategic control post-acquisition. Canada effectively subsidizes the kitchen, lets foreign capital own the food, and then buys the finished pharmaceutical products back from foreign parents at a steep premium.

The Senate Banking Committee reached the same diagnosis in October 2026: a structural gap in scale-up capital, the "missing middle," leads Canadian firms to be "sold prematurely to foreign owners, and thereafter being relocated outside Canada." One witness put it plainly: "Canada is optimized for startup formation… Without stronger scale governance, Canada risks remaining a startup nursery for foreign anchor firms." His comparison, as cited by the committee, puts Canada's startup-to-scale conversion at 0.3%, against 2.2% in the United States and 3.2% in Sweden (Bowie, in Senate BANC, 2026).

Case Studies in Real-Time Access Failure

The health access pipeline compounds this economic loss:

Why the Gaps Persist

This multi-decade gridlock is sustained by three interlocking barriers: how capital is structured, how policy is designed, and how public institutions behave.

1. Capital: Too Small, Too Fragmented, and Too Foreign

2. Policy: Incentives Point the Wrong Way

3. Behaviour: The "Risk-Averse" Institutional Stack

The capital and policy blocks persist because Canadian public institutions operate under a psychological survival mechanism operating as a three-part stack:

This stack produces an ecosystem of anticipatory self-limitation, where institutions stop designing for Canadian-owned scale entirely. It levies a candour tax, where a heavy dependence on single-payer government funding forces industry insiders to self-censor rather than speak candidly about system failures. A reputational self-exclusion dynamic emerges, where qualified commercial leaders rule out working inside legacy government bodies.

While the COVID-19 crisis window proved that hospital digital tools and domestic manufacturing could be deployed in weeks, the system immediately reverted to baseline once the emergency lifted. Paralysis is a policy choice, not a technical limitation.

The Historical Record (The 45-Year Loop of Leakage)

Canada has repeatedly built world-class life sciences assets, only to surrender them at the point they became commercially viable. This loop is embedded in the sector's DNA:

This historical record demonstrates that the reforms required are structural, not motivational. The policy blueprint must rewrite the formulas so that scaling inside Canada becomes the path of least resistance.

Part 2: The Priority Package

Eight reforms do most of the work. They are chosen for leverage and presented in the order a company meets them, from the lab to the patient. The engine is the anchor stage: priorities 5 and 6 make Canadian listings and late rounds investable for Canadian institutional and family capital, so returns stay here and recycle into every earlier stage. Every taxpayer dollar in the package carries incentive-based IP-retention terms (3A.3). Each reform is a full module in Part 3.

The journey has three valleys of financing, each a point where Canadian companies run short of domestic capital and are most often sold or moved abroad. The figure shows the stages that the framework below, and the sections of Part 3, refer to.

The three valleys: an illustrative curve of a life sciences company journey with three funding valleys.

The Intervention Framework

#StageReformWhat it FixesModule
1Lab to companyStreamlined licensing, venture philanthropy and IP retention
(Simple Agreement for Innovation Licensing; national venture philanthropy fund; IP-retention terms on public money)
Months of bespoke licence negotiation drain spinouts, no patient capital carries them to their first round, and IP can leave before a Canadian company forms.3A.1, 3A.9, 3A.3
2Early-stage capital (first valley)Anchor-aligned capital gains exemption
(0% inclusion, up to $15M per business, life sciences and deep tech)
Canada's 50% inclusion rate competes poorly with the 0% U.S. QSBS rate, and today's rules reward a foreign sale as much as staying Canadian. (Note: Protecting investor QSBC status from licensing windfalls is addressed separately in Module 3D.5.)3B.1
3Scale-up (second valley)Late-stage life sciences growth window
(building on the October 2026 Venture and Growth Capital Plan)
Pension tickets of $50M to $75M breach the concentration limits of a typical $150M to $300M Canadian fund, so large rounds go abroad.3C.1
4Scale-up (second valley)Tiered SR&ED Credits for Clinical Trials
(Phase I to IV trials run in Canada; repayment if IP leaves)
Clinical trial exodus. Reverses Canada's declining share of global trials with an enhanced, refundable credit for Canadian-controlled companies' trials, a basic credit for foreign sponsors' Canadian trials, and repayment if credit-funded IP leaves.3E.6
5Anchor stage (third valley)Domestic capital compact
(Tibi model, with a cornerstone IPO sleeve)
Canadian pension funds hold about 18% of their public equities in Canada, and in 2025 Canada had no venture-backed IPOs, so companies list and sell abroad for want of domestic buyers.3D.3, 3D.2
6Scale-up and anchor stage (second and third valleys)Family and philanthropic capital channel
(family offices, donations, foundations, capped rollover pilot)
The intergenerational wealth transfer, family offices and foundation endowments have no structured route into Canadian ventures.3C.6, 3C.5
7Across the journeyTotal Economic Return Procurement Scoring
(Dedicated federal funding for provinces that adopt)
The closed buyer. Lowest-unit-cost public bids lock out domestic innovators. Dedicated federal funding for provinces that adopt the scoring gives them a direct incentive to value domestic economic return.3F.1
8Across the journeyApproved-but-Not-Pursued Exit RegistryLegacy opacity. Fewer than half of approved therapies are even submitted for public reimbursement review, with no public record of the structural or regulatory bottlenecks that caused the exit.3G.1

The Logic of the Flywheel

The flywheel runs top-down from the anchor stage. Once Canadian capital can carry a company to a domestic listing, the returns stay here and fund every earlier stage:

  1. Domestic Capital Makes Listing at Home Viable (Priorities 5 and 6): Pension, institutional and family capital backs Canadian late-stage and listed companies, and the compact's cornerstone sleeve anchors Canadian IPOs.
  2. Exits Pay Out in Canada: Founders, employees, funds and their investors receive their returns at home rather than through a foreign acquisition.
  3. Gains Recycle (Priority 2): The anchor-aligned capital gains exemption rewards holding and keeps that wealth invested in the next generation of Canadian companies.
  4. New Companies Start on Canadian Terms (Priority 1): Streamlined licensing, patient venture philanthropy and IP-retention terms mean the next generation of discoveries forms companies quickly, survives to its first round and keeps its IP in Canada. Philanthropy carries the early risk, universities have a path to impact for publicly funded research, follow-on investors see more companies ready for investment, and Canada keeps the IP.
  5. The Second Valley Is Crossed at Home (Priorities 3 and 4): The late-stage growth window lets Canadian funds lead large rounds, and tiered SR&ED keeps clinical trials here.
  6. A Canadian First Customer (Priority 7): Total Economic Return procurement gives companies domestic revenue and a reference customer at every stage.

The Exit Registry (Priority 8) sits outside the loop and shows where it still leaks. Part 4 sets out the same eight reforms in the order they can be implemented, starting with those that need no new legislation.

Why Boards Sell, and What Changes It

Even companies with access to public markets get sold. Trillium Therapeutics traded on Nasdaq and the TSX, yet in 2021 its board accepted Pfizer's offer at a 118% premium. Boards sell when the return is there, and the answer is not to stop them. It is to change what the board is choosing between: today, one large foreign cheque against a long, uncertain path alone. The package changes that comparison in four ways:

Not every sale should be stopped. The aim is that the companies Canada wants to keep have a real choice, and that assets sold abroad can come home. Octane's 2026 buy-back of the Cocoon platform from Lonza was a boomerang that depended on luck; a repatriation notice and ready Canadian capital make such buy-backs repeatable (3G.1, 3D.3).

Own the Podium for Business

Canadians already know this strategy from sport. Own the Podium, created in 2005 after Vancouver won the bid to host the 2010 Winter Games, stopped spreading funding evenly and concentrated it on the sports and athletes with the best chance of winning medals. It spent $120 million from 2005 to 2010, and Canada won 14 gold medals in Vancouver, the most ever won by one nation at a Winter Olympics at the time (Canadian Encyclopedia). The anchor-company strategy applies the same discipline to the economy, on four principles:

The aim is not to pick individual winners in advance but to decide where Canada intends to compete, fund those areas at a scale that can win, and measure the results in public.

Part 3: The Reform Catalogue

Each module in this catalogue stands alone as an operational blueprint. The provisions are structured under uniform fields to ensure clarity for policy drafters, legislative counsel, and institutional market participants.

The eight sections follow a company from the lab to the patient. The first four take it through the three valleys of financing: from discovery to a fundable company and early-stage capital (the first valley), scale-up capital (the second valley), and the anchor stage of listing and domestic ownership (the third valley). The last four cover what a company needs at every stage: talent and facilities, a first customer, patient access, and the national foundations beneath all of it. Modules marked Priority, with their number, form the eight-reform package set out in Part 2.

SectionWhat it answersModules
3A. From Lab to CompanyDiscoveries stall before they become fundable companies, and early IP leaks abroad.3A.1 to 3A.10
3B. Early-Stage CapitalThe first valley: too few domestic cheques to carry a company from seed to Series A.3B.1 to 3B.7
3C. Scale-Up CapitalThe second valley: rounds above $50M depend on foreign capital.3C.1 to 3C.7
3D. The Anchor Stage: Listing and Domestic OwnershipThe third valley: few Canadian IPOs, thin public markets, and exits that move ownership offshore.3D.1 to 3D.8
3E. Talent, Lab Space and Clinical DevelopmentShortages of scale-stage leaders, wet-lab space, trial infrastructure and domestic clinical trial activity.3E.1 to 3E.10
3F. The First CustomerPublic procurement buys on lowest upfront price and rarely from Canadian firms.3F.1 to 3F.7
3G. Patient Access and ReimbursementApproved products reach Canadian patients late, or not at all.3G.1 to 3G.6
3H. Sovereignty, Data and Supply ChainDependence on foreign supply chains, data platforms and digital infrastructure.3H.1 to 3H.6

The figure in Part 2 shows where each section sits on the journey.

Two gaps on the product's path. The three valleys describe the money. The product itself must also cross two gaps: the translation gap, from discovery to an authorized clinical trial (Section 3A, especially 3A.10), and the health system adoption gap, from regulatory approval to patient access (Sections 3F and 3G). The package addresses both.

3A. From Lab to Company

The first valley sits between the bench and a fundable company; the system currently sends commercialization money through institutions built for research. None of the measures in this section moves ownership of IP to government. They reward keeping IP and companies in Canada, and leave the choice with the institution, inventor and company.

Where Section 3A sits on the company journey

#3A.1 Streamlined and Nationally Harmonized University LicensingPriority

Problem
Each university negotiates licences differently, and many rarely sign the same licence twice, adding months and legal cost to every spin-out. Relocation bans in licences are rarely enforced or are not present, both because universities lack the litigation budgets to enforce them and because they deter private investment in an ecosystem where early investment is already scarce.
Proposal
National adoption of the Simple Agreement for Innovation Licensing (SAIL), a short, streamlined express licence developed by Kyle Briggs, David Durand and Rami Alhamad (introduction). It applies carrot before stick: no unenforceable relocation bans, with retention handled through incentives instead (3A.3). Unlike existing licence frameworks, SAIL encourages universities to absorb costs in support of their spinouts by awarding them equity only in proportion to the value they provide, so adopting universities should charge spinouts little in licensing fees. Adoption is phased. Phase 1: universities volunteer to adopt the licence. A venture philanthropy fund (3A.9) invests separately in their spinouts, for pre-revenue operating costs and the matching funds that government programs require, and covers licensing costs only where a university cannot absorb them. Phase 2: federal and provincial top-ups reward adopting universities, signalling that licensing and spinout activity is a government priority with implications for future funding. Phase 3: once outcome data show the licence works, adoption becomes a condition of Tri-Agency funding. Universities fall under provincial jurisdiction, so Ottawa cannot require a particular licence; what it can do is set conditions on its own research funding, which is the route proposed here.
Precedent
The SAIL initiative (howtosail.ca); UK and U.S. express-licence models, reviewed in Durand and Briggs (2025) (paper).
Evidence
Each Canadian university sets its own IP policy, so licences are negotiated from scratch; the last census of those policies dates from about 2010 (uOttawa), and an updated one would itself be useful.
Impact
Faster, cheaper company formation on terms founders and investors already understand.
Points of Debate
Universities may see express licence terms as giving away value, and many believe every deal is different; SAIL's guidance addresses both objections (SAIL guidance).

#3A.2 A Use-It-or-Share-It Safeguard for Academic IP

Problem
Universities file patent applications readily but face little funding pressure to commercialize them, often because research funders do not make technology transfer a priority in their funding applications, resulting in technology transfer offices that are under-resourced. Under the Patent Cooperation Treaty, national-phase entry falls due 30 or 31 months after the priority date, when costs rise sharply; IP that has found no funding source, licensee or partner by then is often abandoned, and publicly funded inventions lapse unused.
Proposal
A process safeguard, not a change in who owns IP: if a university has not licensed an invention or found a partner by month 24, six months before PCT national-phase entry, the inventors or a spinout receive a right of first refusal to take it at cost, so publicly funded IP is not simply abandoned. Ottawa encourages institutions to adopt the safeguard through funding incentives paid to the university, in place of cost recovery: a university that recovers its patent costs from the inventors or spinout does not also receive the incentive for that invention. Ownership policy itself stays with provinces and universities.
Precedent
Under the U.S. Bayh-Dole Act, if an institution does not elect to take title to a federally funded invention, the funding agency can let the inventor take it. The University of Waterloo's creator-owned policy, under which inventors often assign IP to the university and license it back, shows that the practical difference between ownership models is smaller than it appears.
Evidence
The evidence on ownership regimes is mixed. When Norway abolished the professor's privilege in 2003, university startups and patenting fell by roughly half (Hvide and Jones, American Economic Review, 2018), but other countries have changed in both directions with little effect on outcomes. Reviews of Bayh-Dole and of IP policy conclude that the support structure and processes around IP matter more than who owns it (CanInnovate; Policy Options, 2025), which is why this module targets process.
Impact
Fewer publicly funded inventions abandoned for lack of a licensee, and a route for founders to take forward IP their institution will not.
Points of Debate
Faculty IP ownership is set in provincial university policies and collective agreements, and some provinces have their own structures, such as Quebec's Axelys; a federal mandate would be seen as overreach, so the safeguard should come from provinces or institutions, with Ottawa limited to funding incentives. Universities may resist losing control of IP they paid to file.

#3A.3 Incentive-Based IP RetentionPriority

Problem
Penalties for relocating IP abroad are weak and easily avoided.
Proposal
Earn retention first: repayable public support that converts to a grant if IP and operations stay in Canada, with repayment on transfer abroad. The same earn-retention principle applies across the priority package: public capital deployed through the growth window (3C.1), the domestic capital compact (3D.3) and the SBIR (3A.5) carries incentive-based IP-retention terms, so licensing abroad is encouraged while ownership of core IP stays in Canada. Retention covers where the company operates, not only where its IP sits. Public funding agreements include a recovery clause, declining over a set period such as five years, if the company moves its headquarters, core R&D and staff out of Canada. Recovery turns on substance, not legal domicile: a company that sets up a foreign parent to raise capital, such as a U.S. holding company, owes nothing while its headquarters, R&D and staff stay here.
Precedent
Israel Innovation Authority conditions on transferring funded IP abroad.
Evidence
Israel's retention model. The Senate Banking Committee independently recommended "a variable rate of claw back or repayment mechanism on funded intellectual property should a company sell or move that intellectual property offshore" (Senate BANC, 2026, Recommendation 2). IP is increasingly treated as a question of economic and national security, not only commercial policy (Centre for International Governance Innovation).
Impact
Makes staying the default without blocking exits.
Points of Debate
May deter foreign investors who value flexibility. U.S. investors often require a U.S. parent company as a condition of investing; a clause tied to legal domicile would penalize companies for raising capital, which is why recovery is tied to where people and operations are. Design matters: conditions imposed without support simply create an incentive not to start a company in Canada at all, so support comes first and conditions second. As long as the option to exit is not prevented, the risk of deterring investors is small.

#3A.4 Outcome-Linked Commercialization Offices

Problem
Regional Innovation Centres and technology transfer offices are funded on activity counts, or from their own licensing revenues, which rarely cover operations; in Canada licensing revenue is about 1.7% of university R&D spending (AUTM 2023 Licensing Survey data, as analysed in Durand and Briggs, 2025). Offices are also often understaffed and cannot pay enough to attract people with industry and commercialization experience. Behind the offices sits a reward system: faculty merit, tenure and promotion, and grant review rest mainly on publications and citations, with little weight on economic or societal impact, so creating a company or a licence counts for little in an academic career (Barber and Crelinsten, 2016).
Proposal
Tie 50% of their public operating funding to long-term outcomes rather than licensing revenue: follow-on capital raised by spinouts, and the revenues and employment of companies built on licensed IP, as reported in tax filings, and require IP, transfer and capital-structuring specialists. Pre-seed matchmaking is covered in 3A.7. Apply the same outcome test to federally funded incubators, accelerators and commercialization non-profits, consolidating those that overlap and redirecting the savings to the Canadian SBIR (3A.5). Tie part of that funding to competitive compensation, so offices can recruit and keep staff with industry and commercialization experience. Each office publishes an annual report card: time to licence, use of streamlined licence terms, follow-on capital raised by spinouts, and the number of spinouts that become operating companies, so benchmarking becomes accountability and researchers can choose institutions accordingly. Extend the same outcome review to sector and industry associations that receive government operating funding. Each reports annually against a common set of indicators (companies served, private investment raised by those companies, jobs created and cost per outcome) so funders can see what each taxpayer dollar returns. The aim is to fund what works and scale it, not to cut by default: organizations that show results earn multi-year funding, and overlapping ones are encouraged to merge. Universities and the granting councils give commercialization, industry partnership and company creation explicit weight, alongside publications, in tenure, promotion and grant evaluation, and report on it.
Precedent
Outcome funding in UK Research and Innovation programs. UCeed's annual Momentum Report, which tracks follow-on capital raised by its portfolio companies (UCeed, 2025).
Evidence
Canada has more ecosystem bodies than it can sustain, with fragmented results. Lean, accountable intermediaries exist and should be the benchmark: BioCanRx delivered its national program in 2025–26 with a team of 12, has allocated $40.9 million to immunotherapy research, reports $1.52 in partner funding for every $1.00 it invests, reviews projects every six months and can cancel funding for projects that miss milestones (BioCanRx Annual Report 2025–26). The review should scale models like this, not only cut.
Impact
Pays for outcomes, not meetings.
Points of Debate
Metrics can be gamed or push offices toward short-term deals. Associations also convene, advocate and inform policy, work whose value is hard to count, so indicators should reflect each organization's mandate. Organizations may see the review as a threat; it should be designed and run as a way to identify and fund what works. Counting commercialization in academic careers must not penalize basic research or academic freedom; it should be one recognized route to merit, not a requirement for every researcher.

#3A.5 A Canadian Small Business Innovation Research (SBIR) Program

Problem
Canadian life sciences founders have no reliable, staged, non-dilutive path from proof of concept to prototype. The closest tool, Innovative Solutions Canada (ISC), copied the U.S. SBIR label but not its mechanics: it is a policy target that departments can miss, not a statutory obligation. It spent about 30% of its mandated amount in 2020–21, and the 2024 spending review cut its budget by $70 million a year from 2025–26. Meanwhile, early-stage support is spread across many incubators, accelerators and non-profit intermediaries that overlap and are rarely measured against commercial outcomes.
Proposal
Legislate a Canadian SBIR. Federal departments and agencies with significant extramural health and life sciences R&D budgets (for example, CIHR and the National Research Council) set aside a share of those budgets for competitive awards to Canadian-controlled small firms, phased in from 1% to 3% as research budgets grow, so the set-aside is funded from new money rather than carved out of existing discovery grants (see 3A.8). Awards run in three phases: Phase I feasibility (up to about $250,000 over 6 to 12 months); Phase II prototype and clinical validation (up to about $2 million over 24 months); and Phase III follow-on procurement without a new competition (see 3F.4). Applications are bottom-up: firms propose their own solutions within broad areas, and funding agencies choose what is most valuable, rather than government posting narrow problem statements as Innovative Solutions Canada does. Health-system buyers can add priority topics, so some awards solve problems a buyer has already said it will pay to fix. Awards require Canadian control and are repayable if the funded IP or the company moves abroad within a set period (see 3A.3). Part of the cost is covered by consolidating overlapping federally funded intermediaries, with continued funding tied to measured outcomes (see 3A.4).
Precedent
U.S. SBIR (since 1982), reauthorized in April 2026 through 2031 with foreign-ownership screening and new Phase II "strategic breakthrough" awards of up to US$30 million that require a matching private investment; the UK Small Business Research Initiative; Canada's Budget 2018 commitment to cut 92 business innovation programs by up to two-thirds and route support through four flagship platforms. The U.S. National Institutes of Health runs an omnibus SBIR solicitation that accepts investigator-initiated proposals on any topic within its institutes' missions, alongside a smaller set of targeted topics (National Cancer Institute).
Evidence
An early SBIR grant roughly doubled a firm's chance of later raising venture capital (Howell, 2017). U.S. agencies with more than US$100 million in extramural R&D must set aside at least 3.2%, about US$4.4 billion in FY2022 (CRS). ISC's record shows what happens without statutory force (The Logic). A 2017 federal inventory counted 90 business innovation programs across 20 departments, costing $2.38 billion a year (TBS).
Impact
Gives founders a staged, non-dilutive path through the first valley, keeps early IP Canadian-owned, and feeds firms into the First Outside Equity credit (3B.2) and the first-customer set-aside (3F.4). Because it is phased in from growth in existing research budgets, it needs no separate program appropriation and leaves current discovery grants intact (see 3A.8).
Points of Debate
Researchers may still see the set-aside as competing with investigator-led research; tying the phase-in to budget growth and protecting discovery funding (3A.8) answers this, but slows the ramp-up if research budgets stall. Ottawa can only consolidate intermediaries it funds; many are provincial. The U.S. has "SBIR mills": 22 firms received 50 or more Phase II awards between FY2011 and FY2020, about 10% of Phase II funding. Per-firm caps and commercialization benchmarks address this; the 2026 U.S. law added limits on proposals per firm. A top-down design, in which government decides the problems in advance, is the main reason earlier Canadian attempts have struggled to act as a pull for innovation; the bottom-up design is the point, not a detail.

#3A.6 Platform Funding at Scale: Resurrect the Networks of Centres of Excellence Model

Problem
Uncoordinated short-term grants do not build commercialization infrastructure. Funding is also spread thin across many small grants, so few platforms reach the critical mass needed to compete internationally or attract industry partners, and national programs are often funded for three years and then stop.
Proposal
Re-establish and double-fund the NCE model around national areas of strength. Concentrate funding on a small number of competitively selected national platforms in areas of strength rather than many small grants, on seven- to ten-year terms with renewal based on performance, published outcome reporting, and a wind-down rule for platforms that do not deliver. Platform awards can carry the three-way co-funding of 3E.8.
Precedent
CCRM, built under the NCE program. The Canada First Research Excellence Fund already makes large, seven-year awards with no maximum grant value, about $1.4 billion over seven years in its 2022 competition (CFREF, 2022). BioCanRx, created under the Networks of Centres of Excellence program in 2015, shows a milestone-driven network at work (3A.10). Own the Podium applied the same concentration to sport, targeting funding at events with the best medal chances before Vancouver 2010 (Part 2).
Evidence
NCE hubs created lasting commercialization infrastructure. Short horizons break national infrastructure: the Clinical Trials Fund that supported Canada's clinical trial training platforms was a three-year commitment (see Program Continuity, Part 4).
Impact
Rebuilds connective tissue between science and industry.
Points of Debate
Cost, and why the program was wound down. Concentration means fewer winners, and regions or fields left out will object, so competitions must be open and criteria transparent. Large platforms can become entrenched, which is why renewal depends on performance.

#3A.7 Pre-Seed Researcher-Operator Matchmaking

Problem
Academic founders are expected to handle market execution alone.
Proposal
Pair academic scientists with experienced commercial CEOs from day one, funded at pre-seed. The operators come through the executive-in-residence program (3E.7).
Precedent
European venture-builder and founder-matching models.
Evidence
Commercial leadership is the scarcest talent in Canadian life sciences (3E.1). A few universities, such as Waterloo and, increasingly, Calgary, already pair founders with operators well; the task is to build a national network of people who can do this. Research on start-up mentoring finds that advice from experienced founders improves start-up performance (The Economics of Advice: Evidence from Start-up Mentoring, Management Science).
Impact
Companies start with a market plan, not just a patent.
Points of Debate
Equity splits and fit between scientist and operator.

#3A.8 Protecting Discovery Research

Problem
Several reforms in this blueprint push universities toward commercialization: outcome-linked funding for commercialization offices (3A.4), a use-it-or-share-it safeguard for unlicensed IP (3A.2), and an SBIR set-aside within federal research budgets (3A.5). Everything comes down to incentives. If promotion, tenure, pay and grant decisions come to reward only patents, spin-outs and licensing revenue, researchers will drift toward questions with a near-term commercial payoff, and the curiosity-driven, blue-sky research that produces the breakthroughs future companies are built on could dry up.
Proposal
Build guardrails into the commercialization reforms. First, make commercialization count but never compulsory: federal research funders encourage universities to recognize patents, licences, spin-outs and SBIR awards in promotion and tenure as one optional form of impact, alongside scholarship, teaching and service rather than in place of them. Second, protect the discovery base: the SBIR and translation set-asides (3A.5) are funded from growth in research budgets, not from cuts to investigator-led discovery grants, and Tri-Agency discovery funding is held at least constant in real terms. Third, monitor drift: report each year on discovery outcomes (the share of funding for curiosity-driven research, publications, and funding for early-career researchers) alongside commercialization metrics, so any shift shows up early. Fourth, set clear conflict-of-interest and disclosure rules, and protect graduate students and trainees from being redirected to a supervisor's company work.
Precedent
Promotion and Tenure – Innovation and Entrepreneurship (PTIE), a U.S. initiative funded by the National Science Foundation, which convened universities in 2020 to develop recommendations for recognizing innovation and entrepreneurship in promotion and tenure. Universities, including Oregon State University, adopt its guidelines voluntarily, as an addition to existing criteria rather than a replacement for scholarship (UIDP).
Evidence
A study of 3,862 academic life scientists found that patenting was associated with more publications and had very little effect on their quality, but patenting scientists collaborated more with firms and moved toward research areas that could be patented (Azoulay, Ding and Stuart, 2009). Commercialization and good science can coexist, but incentives do change what researchers choose to study.
Impact
Keeps the discovery pipeline full while the rest of the blueprint builds the commercial pathway, and reassures researchers that commercialization is an option that is rewarded, not a duty that is imposed.
Points of Debate
Universities set their own tenure rules, so federal influence is indirect. A protected discovery budget limits how much funding can be redirected to translation. Drift metrics take years to show results. Some argue that any commercial weighting in tenure will still change behaviour at the margin.

#3A.9 A National Venture Philanthropy Fund for SpinoutsPriority

Problem
Pre-revenue spinouts from publicly funded research need patient, risk-tolerant capital years before private investors will look at them. Conventional venture funds, with 10-year lives, cannot wait: the median time to bring emerging technology to market is about 10 years. Canada ranks last across North America and Europe for the amount of university venture capital available, and a typical Canadian university produces too few companies each year for its own fund to break even. Under SAIL, the university becomes the first investor through an investment instrument such as convertible debt or a SAFE, but someone still has to write the first cheque that carries these companies through the pre-revenue phase to the point where private investment is rational.
Proposal
Seed a national venture philanthropy fund, combining federal money with private donations and contributions from research institutions, that makes many small, founder-friendly investments in pre-revenue companies licensing publicly funded IP. Companies need not use the SAIL licence to qualify, though it makes due diligence faster. All returns are recycled into the next cohort, so the fund becomes self-sustaining. National scope and pooling spinouts from many institutions give it the scale to break even without picking winners before it makes sense to do so; donor-directed sub-funds (for example, a health sub-fund) are permitted; and its cheques can serve as the matching funds startups need to access existing federal programs. Donations to the fund qualify for the private-share donation measure and count toward foundations' disbursement quota (3C.6, 3C.5); this still has to be confirmed with the CRA, though precedents exist at individual universities and in other jurisdictions. Portfolio companies report economic and social outcomes for at least 10 years. The CRA creates a standard registration pathway for commercialization charities, with model objects and investment rules, so venture philanthropy funds do not each have to build the case from scratch. The pathway pairs with the donation and foundation measures in 3C.6 and 3C.5. Canadian disease charities can invest through donor-directed sub-funds, so a patient organization can back therapies for its own disease and recycle any returns into research. Donors can also use a "give plus invest" structure: a charitable gift funds the earliest work, and a minority equity stake follows once the company is ready for investment, so the donor's involvement continues as the company grows. This structure also needs CRA validation, though UCeed already allows it. Matched Canadian seed: when a spinout's first priced round is led by a foreign investor, the fund can offer to match it, so the first outside cheque is not only foreign and early Canadian ownership is not diluted away.
Precedent
The UK model the proposed SAIL Fund adapts, which evaluators estimated created about £7 of economic value for every £1 invested; Oxford's venture philanthropic fund, which took 14 years to break even; UCeed in Calgary, which pools companies beyond a single institution; and the U.S. SBIR at the same early stage (3A.5). Disease charities in the United States already invest this way. The Cystic Fibrosis Foundation put $150 million into Vertex's cystic fibrosis drug program and in 2014 sold its royalty rights for $3.3 billion, money it recycled into research (Scientific American, 2014). The National Kidney Foundation's Innovation Fund, launched in 2021 (NKF), co-invested alongside RA Capital and Biogen in the $93 million Series A of Estuary Biotherapeutics, built on Yale research and developing gene therapies for polycystic kidney disease (BioPharm International, October 16, 2026). The T1D Fund, created by JDRF (now Breakthrough T1D) after its volunteers identified a lack of venture capital for type 1 diabetes in 2016, describes itself as the world's largest single-disease venture philanthropy fund; investing alongside more than 30 venture and biotech funders, it helped direct about $500 million into type 1 diabetes programs within roughly four years (Breakthrough T1D Canada).
Evidence
A simulation built on the funding histories of 9,199 university-affiliated startups in North America and Europe found that many small investments outperform a few concentrated ones. A fund investing $4 million a year broke even in a median of 12 to 15 years and reached a median annualized return of 13.5% after 40 years (Briggs, 2026). Kyle Briggs, David Durand and TJ Misra proposed a national SAIL Fund to the House of Commons Standing Committee on Science and Research in December 2025 (brief). The same founders set out the fund's mechanics in a submission to the 2026 pre-budget consultation.
Impact
Philanthropy carries the early risk with patient capital, universities have a path to social and economic impact for publicly funded research, companies reach the point where follow-on investment is possible, and Canada keeps the IP. It is the first-valley feeder for the anchor-stage engine, and a route for wealth-transfer and foundation capital to reach the earliest stage.
Points of Debate
The fund's own returns are slow and modest, below typical venture targets; its case is catalytic rather than financial. It needs public seed money and a horizon that outlasts political cycles. Charitable status and investment rules require careful work with the CRA. Universities typically prefer royalties for pharmaceuticals and small molecules; SAIL's position is that universities should maximize impact rather than licensing revenue, and that equity through convertible debt is the least likely to deter downstream investment. The lowest-cost route may be to seed the proposed SAIL Fund rather than build a new federal vehicle. Founders of one proposed fund report legal quotes of $70,000 to $150,000 and six to nine months to obtain charitable registration, a barrier a standard pathway would remove. Disease charities that invest must manage conflicts between their role as patient advocates and their stake in a company's product. Any benefit to private investors must remain incidental to the charitable purpose, as CRA rules on undue benefit require (CRA). A stronger option, giving Canadian investors a right of first look before a technology transfer office accepts a foreign term sheet, would slow deals and could deter foreign investors; matching achieves much of the goal without that cost.

#3A.10 A Sovereign Drug Development Fund for the Translation Gap

Problem
Between a published discovery and an authorized clinical trial sits the translation gap: preclinical validation, toxicology, assay development, GMP manufacturing and the dossier for a Health Canada Clinical Trial Application. This work is too applied for health research funding and too risky for most private capital, so it is often abandoned or done abroad. About 70% of Canada's roughly $500 million a year in cancer research investment goes to early-stage research, which does not pay for these steps (BioCanRx Annual Report 2024–25).
Proposal
Endorse and build on the Sovereign Drug Development Fund proposed by BioCanRx: a milestone-driven, expert-reviewed fund that pays for preclinical validation, regulatory readiness and Clinical Trial Application preparation, GMP manufacturing and scale-up, and commercialization and adoption planning, then supports trials with Canadian patients once they are authorized. It has an initial five-year mandate, renewed only on demonstrated outcomes, and projects that miss milestones lose funding. Funded projects must use Canadian research networks and Canadian biomanufacturing, through vouchers linked to facilities already funded under the Biomanufacturing and Life Sciences Strategy. This blueprint adds four conditions: IP licensed on streamlined terms (3A.1) and subject to IP-retention terms (3A.3); clinical funding that meets the regulatory readiness rule (3E.8); open competition across disease areas and organizations; and progress reported to the lab-to-ownership registry (Part 4). The fund is the first-valley plank between licensing (3A.1) and the early-stage, scale-up and anchor measures (3B to 3D), so the package covers the whole path.
Precedent
BioCanRx itself, created in 2015 under the Networks of Centres of Excellence program and funded since 2024 through the Strategic Science Fund: a team of 12, $40.9 million allocated to immunotherapy research, $1.52 in partner funding for every $1.00 invested, and 16 clinical trials treating 422 patients since 2015. Projects are reviewed every six months, and failure to meet milestones can lead to funding being cancelled (BioCanRx Annual Report 2025–26).
Evidence
Less than 1% of cancer immunotherapy trials in Canada originated from Canadian research between 2002 and 2015, rising to 4% from 2016 to 2024, with BioCanRx accounting for 42% of those made-in-Canada trials (BioCanRx Annual Report 2024–25). A lean, milestone-driven model can move discoveries to the clinic; it has not been given national scale.
Impact
Turns Canadian discoveries into Canadian clinical assets before they are licensed abroad, uses biomanufacturing capacity the government has already paid for, and feeds de-risked assets into the SBIR (3A.5) and the capital measures that follow.
Points of Debate
The proposal comes from an organization advocating for its own expansion, and its figures are self-reported and vary across its submissions (for example, 15 or 16 trials and 7 or 8 companies); they should be independently verified before the fund is sized. The fund should be open to all qualified networks and companies, not reserved for one. Requiring Canadian manufacturing can raise costs where domestic capacity is not yet competitive, which the vouchers are meant to offset. The submission does not set a budget, and the fund must be kept distinct from the SBIR (3A.5) to avoid paying twice for the same work.

3B. Early-Stage Capital

Canada does not lack liquid capital; its tax architecture fails to reward early clinical risk, penalizes commercial execution, and permits exit proceeds to permanently leave the innovation ecosystem. Funds that succeed tend to move up to larger cheques, leaving the companies that need $2 million to $5 million behind; as one witness told the Senate Banking Committee, a $500 million fund "can't do 100 investments" (Senate BANC, 2026). What gets rewarded gets repeated: today the tax system treats a gain the same whether a company lists in Canada or is sold abroad, so a quick sale is rewarded as fully as building a Canadian anchor. The anchor-aligned exemption (3B.1) changes that reward.

Where Section 3B sits on the company journey

#3B.1 Anchor-Aligned Small Business Capital Gains ExemptionPriority 2

Problem
Long-term innovation capital faces a 50% capital gains inclusion rate in Canada, while U.S. founders and early backers can use Qualified Small Business Stock (QSBS), which excludes 100% of the gain from federal tax on up to US$15 million per company for stock held five years or more, with partial exclusions after three and four years, under rules expanded in July 2025 (Mintz, 2025).
Proposal
Amend the Income Tax Act (ITA) to introduce a 0% capital gains inclusion rate on eligible long-term small business stock issued by corporations operating primarily in the life sciences and deep technology sectors, capped at a lifetime limit of $15M per business entity. To align the exemption with the anchor strategy, the full 0% inclusion applies to gains realized through a listing on a Canadian exchange or a sale to a Canadian-controlled buyer; gains realized through a sale to a foreign acquirer qualify for a reduced benefit.
Precedent
U.S. Qualified Small Business Stock (QSBS) guidelines under Internal Revenue Code Section 1202; UK Enterprise Investment Scheme (EIS) tax reliefs.
Evidence
The uncompetitive positioning of the standard 50% capital gains baseline creates a stark asymmetry for active venture risk, disincentivizing long-term private positioning relative to international alternatives. Public-market access alone does not keep a company Canadian. Trillium Therapeutics of Mississauga traded on Nasdaq and the TSX and raised capital there, yet in 2021 its board accepted Pfizer's offer of about US$2.26 billion, US$18.50 a share and a 118% premium (Goodwin, 2021). Holding incentives have to change the economics for the directors and investors who decide whether to sell.
Impact
Maximizes incentives for founders, early executives, and domestic angel networks to hold Canadian-incorporated assets through critical mid-stage scale-up milestones.
Points of Debate
Addressing structural critique regarding the concentration of tax benefits among high-net-worth investors; mitigating this via strict caps aligned to active operational deployment. Differentiating the benefit by buyer adds complexity and may draw trade-agreement scrutiny. Qualifying companies must meet the innovation and asset-holding tests in 3D.3, so the exemption does not reward acquisition-driven roll-ups.

#3B.2 First Outside Equity Investment Tax Credit

Problem
Homegrown startups often stall in the "first valley of death" on a continuous public-grant treadmill because landing the initial private outside equity cheque represents a severe transactional bottleneck.
Proposal
Implement a 30% federal investment tax credit applied to the first outside equity cheque issued into an eligible Canadian startup. The credit is structured as fully refundable for qualified independent angel investors and non-refundable for corporate venture funds, governed by strict arm's-length provisions to prevent shell company syndication. Eligibility is restricted to unlisted equity securities to prevent retail public market arbitrage.
Precedent
British Columbia's Small Business Venture Capital Act (Venture Capital Corporation program).
Evidence
Seed rounds in Canada's major tech hubs run 37% to 40% smaller than in comparable U.S. ecosystems, according to the National Angel Capital Organization (Toronto Region Board of Trade, 2026), so the first outside cheque is both harder to find and smaller when it comes.
Impact
Mobilizes private commercial syndicates immediately at the development stage where non-dilutive public research funding concludes.
Points of Debate
Accounting for deadweight fiscal costs where investments might have occurred absent subsidy; neutralized via strict eligibility gating based on operational company age and R&D spend.

#3B.3 Startup Loss Reinvestment Credit

Problem
Due to the power-law dynamics of early-stage venture assets, corporate failures lead to immediate capital contraction as discouraged investors permanently exit the active innovation ecosystem.
Proposal
Introduce a tax credit for accredited investors that allows them to claim an immediate 50% cash-equivalent tax offset based on the total capital loss realized upon an eligible innovation security's dissolution or liquidation, provided they reinvest 100% of any residual asset proceeds alongside fresh capital equal to at least 75% of the total realized loss into another qualifying Canadian startup within 18 months, subject to strict arm's-length conditions. This credit operates as an expansion beyond the existing Allowable Business Investment Loss (ABIL) framework, offering an immediate credit conditional on active asset recycling, rather than ABIL's standard 50% deduction format.
Precedent
Loss-relief features embedded within the UK Enterprise Investment Scheme (EIS).
Evidence
Because the vast majority of seed-stage life sciences plays fail to clear clinical hurdles, sustaining the aggregate size of the investor cohort across successive cycles dictates the survival rate of the broader ecosystem.
Impact
Retains experienced risk capital inside the Canadian corporate framework even following clinical or commercial asset liquidations.
Points of Debate
Managing institutional concerns regarding administrative oversight complexity and the potential to indirectly subsidize sub-optimal investment choices.

#3B.4 Commercialization Matching Credit

Problem
Historical tracking of federal budgets shows an institutional bias toward funding upstream research and discovery over downstream commercial market capture, leaving firms under-capitalized at the point of product launch.
Proposal
Establish a federal matching credit for corporate commercialization expenditures—specifically targeting international sales hiring, global regulatory clearance costs, and channel-partner building—structured to comply with WTO subsidy limits by strictly focusing on domestic operational activity rather than explicit export performance.
Precedent
Formulated as a novel structural instrument designed to transition public support from basic lab inputs to scaled market outputs.
Evidence
A word count of federal budgets from 2012 to 2022 found that research and innovation were mentioned 34 times more often than commercialization (Plant, C.D. Howe Institute, 2023).
Impact
Rebalances corporate operational incentives away from perpetual academic invention toward aggressive global market adoption.
Points of Debate
Resolving verification and compliance monitoring gaps similar to those historically identified within complex input-subsidy programs. No double claiming: salaries already supported by the talent offset (3E.1) are excluded.

#3B.5 Strategic Corporate Venturing Incentive

Problem
Public healthcare delivery systems and provincial single-payer buyers function in isolation from the domestic innovation ecosystem, rarely holding a financial stake in the companies whose therapeutic breakthroughs they require.
Proposal
Enact a federal matching grant program for provincial health authorities and corporate hospital networks, paired with a matching tax credit for domestic pharmaceutical companies, that establish independent, dedicated venture capital subsidiaries focused on investing in early-stage Canadian life sciences startups.
Precedent
Corporate venture capital (CVC) frameworks operating across major U.S. academic medical centres and integrated health networks (e.g., Mayo Clinic Ventures, Kaiser Permanente Ventures).
Evidence
Bridges the operational execution gap that exists between an early-stage venture becoming technically customer-ready and securing institutional investor validation.
Impact
Integrates public health single-payers into active, early-stage financial backers of homegrown medical technology.
Points of Debate
Addressing public sector risk tolerances regarding the deployment of institutional or public capital pools into high-volatility venture assets.

#3B.6 Biotech Flow-Through Shares

Problem
Accredited retail networks, specialized family offices, and domestic institutional investors lack a familiar, highly structured, tax-advantaged equity vehicle optimized for holding long-horizon biopharmaceutical risk.
Proposal
Introduce a specialized Biotech Flow-Through Share (BFTS) regime under the ITA, enabling qualifying life sciences companies to renounce eligible domestic R&D and clinical expenses directly to investors, who can deduct those expenditures against personal income, modelled closely on mining exploration provisions. This allocation is restricted strictly to eligible Canadian R&D expenditures and domestic clinical trial costs that have not already claimed SR&ED credits.
Precedent
The Canadian Mining Flow-Through Share (FTS) regime and the Mineral Exploration Tax Credit (METC).
Evidence
The Canadian capital markets possess an established infrastructure for pricing and trading flow-through structures; applying this mechanism to intellectual property uses existing wealth-management channels. The Senate Banking Committee recommended in October 2026 expanding the flow-through share regime beyond resources to "other capital-intensive industries where early-stage capital requirements precede profitable revenue generation" (Senate BANC, 2026, Recommendation 3). Witnesses named artificial intelligence and defence; life sciences, where clinical spending comes years before revenue, meets the committee's test more squarely than either.
Impact
Opens a large pool of liquid retail and institutional risk capital to finance companies traversing the clinical valleys of death.
Points of Debate
Enforcing legislative guardrails to prevent double-claiming of the same underlying operational expenses against SR&ED tax credits.

#3B.7 IP-Backed Debt

Problem
Canadian lenders rarely accept IP as collateral, so pre-revenue firms can raise only dilutive equity. BDC's $160M IP-Backed Financing fund, Canada's main dedicated program since 2020, is now closed to new investments.
Proposal
A framework that lets commercial banks and lenders use verified IP as collateral for corporate debt: recognized valuation standards, a security registry, and a partial federal loan guarantee to share early losses.
Precedent
BDC's IP-Backed Financing fund; IP-backed lending programs in the United Kingdom, Singapore and China, among other jurisdictions; WIPO's country perspectives on IP-backed financing.
Evidence
BDC closed its IP-backed financing program and cut its deep-tech team in 2025 (The Logic). WIPO and CIPO, Unlocking IP-backed Financing: Canada's Journey (2025) (report); The Logic, 2025.
Impact
Turns intangible assets into non-dilutive working capital and keeps more ownership with founders.
Points of Debate
IP valuation is hard, and recovery after default is uncertain.

3C. Scale-Up Capital

Canada’s primary financing deficit occurs when a scaling firm transitions from laboratory discovery to multi-centre clinical validation, requiring large-ticket growth cheques ($50M-plus) that exceed the concentration limits of typical domestic venture funds. The stages are linked: early-stage investment, growth capital and institutional liquidity "are sequential stages, not separate ones. A weakness at any one stage compounds across the others" (National Angel Capital Organization, in Senate BANC, 2026).

Where Section 3C sits on the company journey

#3C.1 A Late-Stage Life Sciences Growth WindowPriority 3

Problem
Large domestic institutional allocators are structurally locked out of the asset class because tickets of $50M to $75M would breach concentration limits in a typical $150M to $300M Canadian fund, preventing asset managers from entering the sector. CPP Investments' growth equity team looks to invest about US$75 million in life sciences funds that raise US$750 million or more, while Canada's biotech venture funds top out below US$250 million, so Canada's largest pension fund has, in its own words, not yet found "a match" at home (Silcoff, The Globe and Mail, 2026).
Proposal
On October 22, 2026, the government launched a $1.75 billion Venture and Growth Capital Plan. The $1 billion Growth Venture Capital Catalyst Initiative (VCCI) has a $700 million fund-of-funds stream for pension and institutional investors, now taking expressions of interest until January 21, 2027, a $200 million life sciences stream and a $100 million emerging manager stream. A new $750 million Early and Growth Stage Investment Strategy, administered by BDC, adds $75 million for pre-seed and seed and $675 million for later and growth stages, with its design open for comment until November 23, 2026 (ISED, October 22, 2026). This is the right direction, but none of it is yet designed to lead $50 million-plus life sciences rounds: the life sciences stream backs managers from seed to growth with funds as small as $15 million (ISED, 2026), and the later-stage stream is sector-agnostic. Add a late-stage growth window: a life sciences growth fund-of-funds that requires matching institutional allocations, building domestic pools that can write $50 million-plus cheques (and individual growth tickets of $100 million-plus), with fund lives suited to clinical timelines. Build it first from the new Later and Growth Stage Investment Stream, through a dedicated life sciences sleeve that BDC administers on these terms, and add new money in the next budget or the expected federal life sciences strategy if that stream cannot reach life sciences scale. Fund-manager selection gives weight to general partners with operating experience building and running life sciences companies, not only financial track records. Two design features keep the public cost low and the pension return high. First, government backs the fund of funds with a first-loss guarantee rather than cash up front: pension investors are protected against losses at the fund-of-funds level, and public money is paid out only if those losses occur, years later. Second, a reserved follow-on pool, larger than the initial commitment, is set aside for the strongest companies in the underlying portfolios, roughly the top third that are approaching an IPO or sale. Venture managers take the early risk and let weaker companies fail; pension funds then co-invest late, at lower fees and lower risk, in the stage where most value is created. Insulate founders: funds in the growth window and the domestic capital compact (3D.3) may buy a capped share, about 10% to 15%, of founder and early-investor holdings during Series B or C rounds, on commercial terms, on condition that founders stay in their roles and the company meets the substance test in 3A.3. A founder with most of their wealth in one company is under pressure to take the first serious offer; partial liquidity removes that pressure without giving up control.
Precedent
The federal VCCI program models paired with global strategic interventions like Israel’s historical Yozma program, which used state matching capital to de-risk institutional onboarding, and domestic scale successes like Aspect Biosystems in using public-private syndication. Europe's European Tech Champions Initiative (2023), a fund of funds with EUR 3.75 billion from the EIB Group and five member states, backs scale-up funds of EUR 1 billion or more for companies raising more than EUR 50 million. Korea's government-backed fund-of-funds manager, KVIC, has drawn about 4.37 times its public investment in private institutional capital, with dedicated biotechnology and healthcare funds (adMare Institute, 2025).
Evidence
Sourced data from the Sector Task Force confirms that standard Canadian venture funds write capped cheques of $10M to $20M, structurally forcing scaling firms to cross the border for large growth rounds [Pharmaceutical and Life Sciences Sector Task Force, 2026]. Budget 2025 announced the $1 billion initiative as a fund-of-funds designed to draw pension and institutional investors in (Investment Executive, 2025). Measured against the size of the economy, the gap is large: from 2014 to 2024 Canadian life sciences companies raised about one forty-second of what U.S. companies raised, while Canada's GDP is about one-twelfth of the U.S.'s, a notional shortfall of about US$1.5 billion a year. Canadian participation also falls as companies grow, from 42% of start-up deals to 24% of late-stage deals in Canadian therapeutics companies (adMare Institute, 2025). The government expects the plan to draw at least $3.8 billion of private capital, for over $5.5 billion in total across all sectors (ISED, October 22, 2026). Spread across every sector and stage, that is small beside the life sciences shortfall alone.
Impact
Creates a strong domestic late-stage funding layer that reduces dependence on foreign growth syndicates during mid-stage clinical scale-up.
Points of Debate
Addressing institutional allocator aversion to specialized sub-sector mandates by providing clear risk-mitigation structures through public co-investment matching. Using the later-stage stream keeps the cost low but competes with other sectors for the same $675 million; if life sciences cannot secure a sleeve of real size, this requires new money. A guarantee is not free: it is a contingent liability that should be priced and reported, and a guarantee that is too generous weakens investors' discipline. Speed matters as much as design: Budget 2025 announced the initiative, but the fund-of-funds stream opened for expressions of interest only in October 2026 and closes in January 2027, and capital reaches companies only after managers are chosen and raise their own funds, often another year. Critics may see publicly backed funds buying founders' shares as enriching insiders. The purchases are capped, priced commercially and conditional on staying, and are justified only to the extent they keep the company independent through the scale-up years.

#3C.2 Stackable Capital and Accepting Failure

Problem
Canadian programs fund in isolated silos and penalize visible failure, so they miss breakout winners (a hidden false-negative cost).
Proposal
Blend non-dilutive grants, low-interest loans and public co-investment on one cap table, and judge programs on portfolio returns rather than individual failures.
Precedent
Bpifrance; the European Innovation Council Accelerator.
Evidence
Venture returns follow a power law; a few winners return the portfolio.
Impact
Larger, better-structured rounds.
Points of Debate
Public accountability rules are built around avoiding individual losses.

#3C.3 Linked Funds and Pooled Hospital Foundation Capital

Problem
Canadian seed rounds are small relative to the cost of drug and device development, forcing slow, underfunded progress. Meanwhile, hospital foundations, such as those along Toronto's University Avenue, hold substantial balances that rarely reach early-stage companies.
Proposal
Back funds that pair seed investment with reserved follow-on growth capital, and pool hospital foundation capital into multi-hospital translational funds linked directly to those growth reserves.
Precedent
The Cancer Breakthrough Fund, launched in 2025 by Lumira Ventures and the Terry Fox Foundation (later joined by the Canadian Cancer Society), raised in parallel with Lumira's core Fund V: charitable capital linked directly to venture growth capital (announcement).
Evidence
Canadian seed rounds averaged about $3.0M in the first half of 2025 (CVCA); Canadian life sciences VC fell to $837M in 2025, its lowest since 2018 (BetaKit).
Impact
Companies funded to milestones rather than survival, with mission-aligned capital behind them.
Points of Debate
Larger reserves mean fewer companies funded; foundation boards will weigh risk to donor money.

#3C.4 Permanent and Evergreen Capital

Problem
Venture funds run on 5- to 10-year horizons and are structurally built to exit; they are not Berkshire Hathaway. Thirty-year anchor companies need owners who do not have to sell.
Proposal
Pair early venture capital with patient, permanent vehicles: pension funds, public markets, evergreen foundations and integrated family-office platforms that can hold companies through scale.
Precedent
Evergreen models such as TIAP, the SAIL Fund and Give Back; the Novo Nordisk Foundation's permanent ownership of Novo Nordisk; family-office platforms such as Wittington.
Evidence
Fund lifecycles force sales at the value inflection point.
Impact
Ownership that can stay through scale.
Points of Debate
Permanent capital can protect underperformers.

#3C.5 Foundation Disbursement Quota ReformPriority 6

Problem
Under the federal disbursement quota (DQ), registered charities, including public and private foundations, must spend 3.5% of investment assets up to $1 million and 5% of assets above $1 million each year (rates in force since 2023). This rule penalizes foundations that back high-growth, illiquid domestic venture assets, forcing artificial asset liquidations to meet short-term cash distribution rules.
Proposal
Amend the ITA to permit direct capital allocations into eligible Canadian life sciences and deep-tech venture funds to count toward a foundation's annual 5% disbursement quota requirement, legally treating domestic risk-capital commitments as a qualified output.
Precedent
Formulated as a novel structural expansion of qualified disbursement parameters, expanding beyond standard grant-making models to address long-horizon commercialization capital.
Evidence
Canadian philanthropic foundations manage massive aggregate asset bases, yet structural regulatory friction restricts these endowments from deploying risk capital into domestic innovation ecosystems.
Impact
Brings in patient, multi-decade philanthropic capital pools capable of backing long-horizon therapeutic development without forcing premature asset liquidation.
Points of Debate
Tax-receipted charitable dollars could end up generating private financial returns instead of being directly deployed to core front-line charitable work; requires strict governance metrics to ensure that capital is directed strictly to high-impact Canadian therapeutic discovery.

#3C.6 Family and Philanthropic Capital: The Intergenerational Wealth TransferPriority 6

Problem
Canada is in the middle of the largest wealth transfer in its history: about $1 trillion was expected to pass from baby boomers to their children between 2023 and 2026 alone, and over $2 trillion in small business assets could change hands within a decade. Nothing in the tax system steers this capital toward Canadian innovation. Estates face a deemed disposition at death and are reinvested in conventional portfolios, and family offices and foundations have no structured route into domestic ventures.
Proposal
Build a family and philanthropic capital channel in three parts. First, family offices invest through the domestic capital compact (3D.3) and the federal fund-of-funds stream (3C.1) on the same terms as pension funds. Second, revive the Budget 2015 measure exempting capital gains on private shares and real estate when the proceeds are donated to a registered charity, extended to charities and donor-advised funds that invest in Canadian ventures (see 3C.5). Third, pilot a capped Canadian Innovation Rollover: defer capital gains tax on the sale of a business or an estate's deemed disposition when the proceeds are reinvested within 12 months in labelled funds and held for at least seven years, with public reporting on where the capital goes.
Precedent
France's Tibi initiative, whose 37 signatories include two family offices (Trésor, 2025); U.S. Qualified Opportunity Funds (2017), which defer capital gains reinvested in designated funds; the U.S. Section 1045 rollover of qualified small business stock gains; Canada's Budget 2015 private-share donation measure, announced and then withdrawn in Budget 2016 (Fasken). In British Columbia, an angel investor can claim the provincial venture capital tax credit on an investment in an eligible startup and then donate the shares to a charity, such as a university, claiming a donation credit on their value. Stacking the 30% angel credit with the maximum charitable credit can return up to about 82 cents per dollar invested for a donor in the top tax bracket, and less for most donors (Briggs, CanInnovate).
Evidence
CPA Canada estimated about $1 trillion would pass between generations from 2023 to 2026 (CBC News, 2025). Over three-quarters of small business owners plan to exit within ten years, putting over $2 trillion in business assets in play, and fewer than one in ten has a formal succession plan (CFIB, 2023). The Senate Banking Committee recommended deferring capital gains on the sale of Canadian SME shares when proceeds are reinvested in other Canadian SMEs within a set period (Senate BANC, 2026, Recommendation 3).
Impact
Turns a one-time generational event into long-horizon domestic capital, and gives family offices and foundations a structured route into Canadian ventures alongside institutional investors.
Points of Debate
Fiscal cost, and the optics of tax relief for wealthy estates. The closest U.S. precedent, Opportunity Zones, saw capital concentrate in a few places and more than half go to real estate, with little measurable job gain (Center for American Progress, 2022), which is why the rollover starts as a capped pilot restricted to labelled funds. Capital may chase the tax relief rather than good companies, so qualifying funds need professional management and reporting standards. Overlap with the capital gains exemption (3B.1) must be managed to prevent double benefits.

#3C.7 A Safe Harbour for Philanthropic and Impact Introducers

Problem
Life sciences depends on small connectors: the advisers, former executives and philanthropic intermediaries who introduce foundations, family offices and patient-minded investors to early companies. In Canada, a person who is paid to connect investors with a company is generally treated as being in the business of trading and must register as a dealer, usually an exempt market dealer, with the exams, capital and compliance costs that come with it. There is no clear safe harbour for introducers whose role stops at the introduction, and no proportionate category for impact and philanthropic intermediaries. The people best placed to bring patient capital to first-valley companies either work unpaid, work in a grey zone, or stay out.
Proposal
The Canadian Securities Administrators create two things. First, a safe harbour for introducers who only connect issuers with accredited investors, foundations and family offices: no advice on valuation or suitability, no negotiating terms, no handling of money or securities, a written agreement with the issuer, and written disclosure to investors of the introducer's relationship and compensation, with limits on the number and size of transactions each year. Second, a lighter registration category for impact and philanthropic intermediaries, with proficiency and capital requirements proportionate to their activity. Both are tested first through the CSA Regulatory Sandbox and provincial innovation offices.
Precedent
The U.S. Securities and Exchange Commission proposed a two-tier exemption for finders in October 2020: Tier I finders could pass on investor contact information only, and Tier II finders could solicit accredited investors on an issuer's behalf, subject to disclosure and a list of prohibited activities (Morgan Lewis, 2020). The proposal was not finalized, but it shows how a narrow, conditional exemption can be drawn.
Evidence
The Senate Banking Committee recommended reducing reliance on a small number of large institutions by supporting diversified channels for SME financing, including small dealers, smaller-scale private investment firms and alternative platforms, and found that the regulatory structure imposes a high administrative burden on dealers trying to bring investment to Canadian SMEs (Senate BANC, 2026, Recommendation 6). Most capital-markets reform debate focuses on exchanges and institutions and overlooks the small connectors that early-stage life sciences relies on.
Impact
More philanthropic and patient capital reaches first-valley companies through the people who already know them, under rules that protect investors.
Points of Debate
Unregistered finders have been a source of investor harm, which is why regulators narrowed earlier exemptions; the conditions must keep advice and money-handling inside registration. Introducers paid by success fee have a conflict of interest that disclosure only partly manages.

3D. The Anchor Stage: Listing and Domestic Ownership

The third valley sits at the anchor stage, when a company that has survived scale-up must either list and keep growing as an independent Canadian company or be sold. Canada's public markets have shrunk, and too many exits end in foreign ownership (see Part 1). This section covers the public-market, ownership and governance tools that let companies become Canadian anchors. Not every sale is a loss. Acquisitions return capital to founders and investors, and experienced founders often go on to build the next company; each of the seven largest foreign acquisitions of Canadian therapeutics companies since 2013 still operates in Canada, employing hundreds of people (adMare Institute, 2025). The aim is not to block exits but to make sure a company sells because a sale is the best outcome, not because Canadian capital ran out. That judgment, between a real constraint and an excuse, is what these tools are meant to inform.

What counts as Canadian. Three tests are in use, and they are often confused. Tax: a Canadian-controlled private corporation (CCPC) is private and not controlled by non-residents, so the status ends when a company lists; since Bill C-15, the enhanced SR&ED rate also reaches eligible Canadian public corporations not controlled by non-residents (3E.6). The Investment Canada Act: whether a business is Canadian-controlled is decided when someone proposes to acquire it, mainly by who holds the voting interests; it is a test applied at the moment of acquisition, not a status a company carries. Substance: where headquarters, senior management, R&D and the ownership of core IP actually sit (3A.3). A company can pass one test and fail another. AbCellera, for example, is incorporated and headquartered in Vancouver but listed only on Nasdaq, so most of its investor base and trading sit outside Canada. This blueprint uses substance plus control: incentives go to companies that keep headquarters, R&D and core IP in Canada and are not controlled by non-residents, rather than to a set percentage of Canadian share ownership. Ownership follows capital; the measures in this section are meant to make sure Canadian capital is there when it matters.

Where Section 3D sits on the company journey

#3D.1 A Canadian Growth Savings Account

Problem
Canada's public markets are shrinking just as its life sciences companies need them. The number of companies listed on the TSX and TSXV fell from 3,520 in 2008 to 2,114 in 2024, and new listings fell from an average of 47 a year in 2008 to 2013 to 16 a year from 2014 to 2024. Canadian household savings flow overwhelmingly into index funds and established large caps, so a Canadian life sciences company that lists at home finds few domestic buyers for its shares.
Proposal
Create a Canadian Growth Savings Account: a registered, tax-free account, with an annual contribution limit, in which at least 70% of holdings must be newly issued shares of Canadian-headquartered life sciences and deep-tech companies listed on Canadian exchanges, or professionally managed funds that hold them. Gains become tax-free only after a five-year hold. Learning from Quebec's experience, the incentive rewards holding rather than buying: there is no upfront deduction, and retail investors are steered toward diversified funds rather than single small-cap issues.
Precedent
The Quebec Stock Savings Plan (1979 to 2005), which gave deductions for buying new shares of Quebec-headquartered companies; Italy's Piani Individuali di Risparmio (2017), which exempt gains from tax when savings invested in Italian companies, including smaller listed firms, are held for five years, up to €30,000 a year.
Evidence
Canada's listed-company count and IPO volumes have fallen sharply since 2008 (Fraser Institute, 2025). The Quebec plan's upfront deductions produced a short burst of small-company listings, many of which later failed, leaving investors with large losses; its evaluators judged it an ineffective stimulant for small-company listings (Cormier and Suret, 1997). Italy's plans were expected to channel almost €2 billion into SMEs listed on AIM Italia (Nexia, 2018).
Impact
Builds a domestic investor base for Canadian listings, deepening liquidity so that life sciences companies can list, raise follow-on capital and stay headquartered in Canada.
Points of Debate
Fiscal cost. Retail investors carry real risk in a sector where most clinical programs fail, which is why the design favours diversified funds. The Quebec record shows a poorly designed incentive can damage investor confidence for years. Benefits may flow mainly to households that already have room in their TFSA and RRSP.

#3D.2 A Canadian Cornerstone IPO FundPriority 5

Problem
A life sciences IPO needs an anchor order: a credible investor who commits early to a large share of the offering so others follow. Canada has few specialist public-market investors able to play that role, so Canadian companies that reach IPO scale often list in the United States, where specialist funds anchor the book, and their ownership, analysts and eventually their headquarters follow the capital. The exchanges are not the problem: TMX Group runs the TSX and TSX Venture nationally, alongside the CSE and Cboe Canada. The problem is securities regulation. The United States has one federal regulator; Canada has 13 provincial and territorial regulators. Under the passport system one lead regulator reviews a prospectus, but filings and fees still go to each jurisdiction. The split also affects who can invest. When a Canadian company lists only in the United States, it files no Canadian prospectus, so Canadian institutions can buy only under specific exemptions; the 2015 relief that lets Canadian institutions join U.S. offerings without a Canadian prospectus "wrapper" covers foreign issuers, not Canadian ones (Davies, 2015).
Proposal
Capitalize a Canadian Cornerstone IPO Fund, co-funded by the federal government and participating pension funds (see 3D.3) and run on commercial terms by an independent manager. The fund takes cornerstone positions in IPOs and follow-on offerings by Canadian-headquartered life sciences and deep-tech companies that list on a Canadian exchange (dual listings permitted), invests on the same terms as private investors, accepts a lock-up period, and requires the company to keep its headquarters and core IP in Canada for a set period. The fund can operate as the listed-company sleeve of the domestic capital compact (3D.3), run by private managers, rather than as a standalone public fund. The fund can also take cornerstone positions in Canadian companies that repatriate Canadian-origin assets, including the financing of a buy-back ahead of a domestic listing. Pair the fund with a single national securities regulator, completing the cooperative capital markets system, or, short of that, one prospectus review and one fee that every province and territory accepts. Extend the 2015 institutional offering relief to Canadian-headquartered companies, so Canadian pension funds and institutions can take part in their U.S. offerings on the same terms as in foreign companies' offerings. The ask is about regulation and investor access, not merging exchanges. Where a company lists with dual-class shares, the fund takes part only if the enhanced votes are time-limited, expiring after about 10 years unless renewed by ordinary shareholders, and convert to ordinary shares if the founder leaves or sells them. The enhanced votes can also be limited to approving a change of control, so that ordinary governance stays one share, one vote while a sale abroad still needs the founders' consent. Canadian law already permits dual-class listings, so this is a condition on public cornerstone money, not new legislation, and it complements the foundation trust (3D.4) for companies that do not want one.
Precedent
Singapore's Anchor Fund @ 65 (2021), an initial S$1.5 billion fund co-funded by the government and Temasek and managed commercially by 65 Equity Partners, created to help high-growth companies list at home; cornerstone allocations are also a standard feature of Hong Kong IPOs.
Evidence
Singapore launched its fund specifically to help high-growth companies raise capital through local listings (EDB Singapore). Canada's average annual IPO count fell by about two-thirds between 2008 to 2013 and 2014 to 2024 (Fraser Institute, 2025). The small-cap route closed long before that. Annual counts by Tony Pullen, a former Canadian healthcare investment banker, show that of roughly 150 public Canadian healthcare companies in 2007, only about 60 survived to 2013, and companies valued at $50 million to $200 million, the range where institutional interest in Canada begins, fell from 40 to 19 (Pullen, 2013). By 2016, 71 of 87 listed Canadian life sciences companies traded at least 80% below their all-time highs and 46 at least 95% below, and the companies outside the largest few averaged about $56 million in value: too many companies chasing too few dollars (Pullen, 2017). This happened while the Nasdaq Biotechnology Index quadrupled between 2012 and 2015, so it was not a cyclical dip: Canada's small-cap market stopped working as a financing route for biotech even in a global boom. The pattern continues today. Aurinia Pharmaceuticals, headquartered in Victoria, won FDA approval for its lupus nephritis drug LUPKYNIS in January 2021 and runs its commercial operations from a U.S. office in Rockville, Maryland, with its shares registered on Nasdaq (Aurinia, 2023). Vancouver's NervGen Pharma delisted from the TSX Venture Exchange in March 2026 to trade only on Nasdaq, saying that as it entered late-stage development a Canadian listing no longer justified its costs (NervGen, 2026). Clinical-stage Canadian companies such as NervGen, Satellos and Medicenna are followed by U.S. investor communities, including subscription forums for physician and scientist investors, more closely than by Canadian institutions. When the investors who follow and fund Canadian biotech are American, the listing, the analysts and eventually the company follow them. A large life sciences IPO can price at home: Apotex's June 2026 offering, expected to raise about $1.3 billion, was the largest life sciences IPO in TSX history by proceeds, and 110 life sciences companies were listed on the TSX and TSX Venture with a combined value of $26 billion as of May 31, 2026 (TMX Group, 2026). Apotex is a generic manufacturer, so it shows the market's capacity rather than a path already open to innovative biotech.
Impact
Gives Canadian listings a credible anchor, so companies can price their IPO at home and grow into independent, Canadian-headquartered anchor companies rather than being sold at the first large offer.
Points of Debate
Government capital in public offerings raises concerns about picking winners and distorting prices, which commercial management and same-terms investing are meant to address. The fund could crowd out private cornerstone investors. Headquarters conditions may deter some issuers. Singapore's fund and its sister IPO fund had invested in nine companies by February 2024, with no IPOs reported (MTI, 2024): a cornerstone works only alongside broader institutional demand, which is why it sits inside the compact. A national regulator has been debated for decades: the Supreme Court found the cooperative system constitutional in 2018, but Quebec and Alberta declined to join and the system has not launched. The passport system already lets one regulator lead a review, so the gain is in speed, cost and a single rulebook rather than a new right to list. Governance advocates oppose dual-class shares because they can entrench founders and separate control from economic ownership; the sunset, the conversion triggers and the change-of-control limit are designed to answer that, and the trade-off should be reviewed as evidence on Canadian listings accumulates.

#3D.3 Domestic Capital Compact: Institutional Asset MatchingPriority 5

Problem
Broad domestic institutional portfolios maintain a structurally depressed allocation to Canadian public and private equities, leaving multi-billion-dollar domestic liquidity pools detached from anchoring scaling national biotechs.
Proposal
Implement a voluntary institutional matching framework that links federal co-investment matching and structural risk-mitigation guarantees directly to domestic asset allocations into Canadian innovation equities, specifically targeting late-stage growth rounds and public life sciences anchors. Family offices and foundations can join the compact on the same terms (3C.6). The compact includes a repatriation sleeve: capital ready to back Canadian buyers when a foreign owner divests a Canadian-origin asset flagged through the registry (3G.1), so boomerangs are repeatable rather than lucky. Safeguard against roll-ups: anchor incentives reward companies built on innovation and on holding assets, not acquisition-driven roll-ups. Eligibility for the compact's labelled funds, the cornerstone sleeve and the anchor-aligned exemption (3B.1) depends on sustained R&D spending in Canada and on value coming from owned or developed IP, with limits on debt-financed acquisition strategies.
Precedent
Modelled closely on France's Tibi Initiative, which successfully mobilized leading institutional investors to collectively pledge and deploy multi-billion-euro allocations into specialized domestic technology and venture funds [Direction générale du Trésor, 2025]. The Senate Banking Committee recommended aggregation vehicles to channel institutional money into Canadian SMEs, using tax treatment, co-investment and potential federal guarantees (Senate BANC, 2026, Recommendation 5). The UK's Mansion House Compact (2023) drew voluntary commitments from large defined contribution pension providers to invest in unlisted equities; its 2025 successor, signed by 17 providers, raised the target to 10% of default funds by 2030, with at least half in the UK. Ireland's Strategic Investment Fund has a dual mandate of commercial returns and domestic economic activity, investing EUR 20 million-plus tickets; it reports EUR 2.3 billion in returns and EUR 11.1 billion of private co-investment (adMare Institute, 2025).
Evidence
Domestic equities comprise approximately 18% of large pension public equity portfolios, a severe multi-decade decline down from 33% in 2013 [Betermier]. Across total AUM, domestic equities sit at a mere ~3% [New Financial, 2024]. Since 2020, Tibi investors have committed €12.5 billion to labelled funds, which have raised nearly €30 billion and take part in more than half of French rounds above €50 million (Trésor, 2025). Octane shows that a boomerang is possible. Its Kingston-invented Cocoon cell therapy manufacturing platform passed to Swiss-based Lonza when Lonza took a controlling stake in Octane Biotech in 2018. In March 2026 Octane agreed to buy back Lonza's Personalized Medicine business, including Cocoon, its IP, workforce and customer contracts, and the transfer completed on April 2, 2026 (Octane, 2026; Lonza, 2026). It happened because Lonza chose to divest; nothing in Canadian policy made it likely. The "Maple Eight" public pension funds managed $2.3 trillion at the end of 2024, with domestic investment at less than half the global industry average (Senate BANC, 2026). Canadian money is thin even at the limited-partner level: of the disclosed limited partners behind the funds that financed the top 20 Canadian therapeutic exits, 81% were American and 6% Canadian, and across all 281 disclosed funds the Canadian share was 10%. These are counts of investors, not dollars, from partial disclosure (funds were disclosed in 70% of deals and limited partners in 39% of those), and some Canadian institutional money sits inside international funds (adMare Institute, 2025). Pension and retirement funds made up 38% of the disclosed limited partners behind those top 20 exits, but only two were Canadian: the Caisse de dépôt et placement du Québec and the Fonds de solidarité FTQ (adMare Institute, 2025).
Impact
Re-mobilizes large-scale domestic institutional asset pools to step in as lead buyers and long-term hold investors in Canadian biotech platforms.
Points of Debate
Addressing potential institutional concern regarding independent portfolio autonomy and political distortive pressures on asset manager mandates. The compact does not mandate allocations. Pension funds owe a fiduciary duty to their members, and a Global Risk Institute study warns that mandates could harm plan members (Benefits Canada, 2024). Instead the compact changes the risk and return of investing in Canada, through co-investment matching, a fund of funds sized to pension tickets and risk-mitigation structures, so that a domestic allocation is a prudent choice on its own terms. Large funds such as CalPERS invest in biotech because their boards judge the returns worth it, not because a government requires it. Canada's largest healthcare market values of the last two decades show why the safeguard matters. Valeant grew from Biovail into a market value of roughly $55 billion by the end of 2014 through acquisitions financed on Wall Street, then fell to about $6.6 billion by 2016; Concordia went from a $35 million listing in 2013 to a peak value near $4 billion through acquisitions and collapsed by 2016 (Pullen, 2015; Pullen, 2017). Neither built a Canadian anchor. CPP Investments is a special case. Its legislation requires it to invest for a maximum rate of return without undue risk of loss, at arm's length from government, a commitment made to Canadians when the CPP Investment Board was created in 1997 (CPP Investment Board Act). The compact respects that: it asks nothing of CPP Investments, and CPP takes part only if the returns justify it on their own merits.

#3D.4 Sovereign Bio-Foundation Trust Framework (The Denmark Model)

Problem
Emerging Canadian biotechnology firms requiring growth rounds of $50M-plus to complete Phase II/III clinical trials are forced to rely heavily on foreign venture capital. This dependence routinely results in yielding board majorities and strategic control, driving the eventual relocation of intellectual property and corporate headquarters outside Canada. At the anchor stage, the same pattern decides who controls the company: once foreign investors hold the majority, a sale abroad becomes the default exit, and Canada loses the anchor company it helped build.
Proposal
Establish a federally chartered, asset-backed Sovereign Bio-Foundation Trust (SBFT) designed to introduce a Canadian adaptation of the dual-class foundation model. The SBFT, capitalized via public allocations matched by participating domestic institutional funds, co-invests in late-stage, high-potential life sciences firms approaching public markets. The SBFT purchases unlisted Super-Voting Class A shares (carrying high voting control but minimal economic distribution rights), while international commercial venture syndicates purchase standard Subordinate-Voting Class B shares (carrying high economic value but capped voting weight).
Precedent
The Danish Foundation Model, where the Novo Nordisk Foundation maintains 77.3% voting control through 28.1% of the total share capital via its wholly owned investment subsidiary Novo Holdings A/S, legally insulating the operating firm from foreign corporate takeovers while absorbing global market investment capital [Novo Nordisk Annual Report 2024].
Evidence
Comprehensive ecosystem tracking demonstrates that international investors comprise 76% of participants in Canadian growth rounds exceeding $50M, and 67% of deal volume [adMare Institute, 2025; Pharmaceutical and Life Sciences Sector Task Force, 2026]. TSX dual-class listings with strong coat-tail provisions are an established corporate governance mechanism across Canadian industry [Dual-Class Share Structures in Canada, IGOPP].
Impact
Permits Canadian scaling champions to absorb massive international growth financing rounds up to IPO while legally anchoring corporate headquarters, key leadership, and foundational IP within Canada.
Points of Debate
Critics note that the Novo Nordisk Foundation was built on a founding asset, insulin, whose profits sustained it for a century, and that Canada has no single asset like it today. The trust does not need one: it is capitalized by public allocations matched by domestic institutions and holds control stakes across a portfolio of anchor-stage companies, so its founding asset is the pipeline of discoveries Canada already funds. Denmark itself shows the structure does not depend on one discovery: the Lundbeck Foundation and the LEO Foundation also control their pharmaceutical companies, an arrangement credited with protecting Danish firms from hostile takeovers (The Local, 2016). Canada did have its founding asset: Connaught Laboratories manufactured insulin for decades, was federally owned from 1972 and was sold in 1986. The asset existed; the vehicle to keep it did not. Some will see a publicly capitalized trust holding voting control as nationalization by another name. It is not: companies choose to take its investment, the trust is arm's-length and barred from political direction, it takes no operating role, and its control is limited to blocking a sale or move abroad.
  • Capital Constraints: Foreign venture funds may refuse to invest under capped voting rights, potentially shrinking the accessible growth capital pool.
  • Public Return: Public money pays for governance control while securing minimal economic return to taxpayers.
  • Trade Integrity: A state-backed trust holding structural voting control may draw intense trade, CETA, or national-treatment regulatory scrutiny.

Statutory Governance Guidelines for the SBFT Board

To ensure the Sovereign Bio-Foundation Trust remains insulated from political interference, macroeconomic policy shifts, and public procurement lobbying, its charter must be governed by the following statutory framework:

  1. Fiduciary Mandate and Legal Independence: The SBFT will be established via a dedicated Act of Parliament as an independent, arm's-length corporate entity. Its sole statutory mandate will be the maximization of long-term commercial scale and the domestic anchoring of intellectual property within Canada. The Act will prohibit the Minister of Innovation, Science and Economic Development, the Minister of Health, or any agent of the Crown from issuing binding policy directives or altering investment allocations regarding individual corporate assets or specific therapeutic pipelines.
  2. Board Composition and Qualifications: The Board of Directors will consist of 9 members. Seats are restricted based on objective commercial and scientific criteria:
  1. Appointment Mechanics and Self-Perpetuation: The initial foundational board will be appointed by an independent, non-partisan merit-based selection committee consisting of representatives from the Council of Canadian Academies and the Canadian Association of Pension Supervisory Authorities (CAPSA). To eliminate political patronage loops, all subsequent vacancies on the Board will be filled via a self-perpetuating nomination process. The active Board will source, vet, and elect replacement members based on the skill-gating criteria, independent of Privy Council Office approval or Cabinet confirmation. Industry advocacy associations are legally barred from maintaining direct selection committee seats to eliminate conflicts of interest.
  2. Capital Insulation, Accountability, and Operational Autonomy: The federal capitalization commitment to the SBFT will be structured as a one-time, permanent statutory appropriation drawn directly from the Consolidated Revenue Fund. It will not be subject to annual Parliamentary appropriations or Treasury Board reviews. To ensure institutional accountability, the SBFT will be subject to mandatory annual audits by the Auditor General, file comprehensive annual reports directly to Parliament, and undergo an independent legislative mandate review every five years. To attract top-tier global life sciences talent, the executive leadership of the SBFT will be compensated outside the standard Public Service Employment framework, indexed to private sector benchmarks.

#3D.5 Safe Harbours for Commercial Success

Problem
The current tax code penalizes positive commercial outcomes: receiving milestone licensing revenues can push a firm out of compliance with the 90% active-asset test, causing investors to lose their QSBC status; meanwhile, securing foreign growth capital can strip a firm of CCPC status, gutting enhanced SR&ED refundability.
Proposal
Amend the Income Tax Act definitions of a qualified small business corporation share (subsection 110.6(1)) and a small business corporation (subsection 248(1)) to introduce a statutory safe harbour treating pharmaceutical licensing windfalls as active operational assets for a rolling 36-to-48-month window, provided the capital is earmarked for domestic R&D. Concurrently, enact a transition rule preserving enhanced SR&ED parameters for a fixed three-year period following a cross-border growth round, conditional on the company retaining its primary R&D infrastructure and headquarters in Canada. This directly addresses the historical regulatory cliff by adjusting the framework to sit alongside recent baseline expansions under Bill C-15. Specifically, C-15 extended enhanced SR&ED to eligible Canadian public corporations, but not to private companies that become foreign-controlled, and it left the active-asset test unchanged.
Precedent
Existing interpretive tax relief frameworks governing short-term working capital allocations.
Evidence
Current active-asset tests inadvertently function as structural disincentives, discouraging early commercial monetization and cross-border capital syndication.
Impact
Allows scaling firms to absorb international venture financing and close global licensing partnerships without triggering domestic tax penalties.
Points of Debate
Ensuring monitoring mechanisms are sufficiently rigorous to prevent firms from using the safe harbour to shelter passive, non-operational corporate cash.

#3D.6 Employee and Management Buyouts

Problem
Most Canadian founders exit by selling, and in life sciences the buyer with cash is usually foreign. Over three-quarters of small business owners plan to exit within a decade, yet fewer than one in ten has a formal succession plan. Employee and management buyouts can keep a profitable company Canadian-owned, but employees rarely have the capital, and lenders seldom finance these deals.
Proposal
Build on the now-permanent $10 million capital gains exemption for sales to an Employee Ownership Trust (EOT) with three measures: a BDC buyout-financing window, with partial loan guarantees, for EOT and management buyouts of Canadian-controlled life sciences firms such as CDMOs, CROs, device makers and diagnostic labs; tax-deductible company contributions to an EOT when used to repay the buyout debt; and a higher exemption ceiling where the buyer commits to keep IP, headquarters and manufacturing in Canada for a set period.
Precedent
U.S. Employee Stock Ownership Plans (ESOPs), where company contributions used to repay the buyout loan are tax-deductible; UK Employee Ownership Trusts (2014), which give sellers full capital gains relief; Canada's EOT regime (2024) and the permanent exemption enacted in June 2026. The Senate Banking Committee urged the government to consider using BDC, the Canada Growth Fund or other federal sources to finance Canadian acquisitions of Canadian companies, particularly in succession (Senate BANC, 2026).
Evidence
Bill C-30 received royal assent on June 18, 2026, making the EOT exemption permanent (Wealth Professional). CFIB found 76% of owners plan to exit within ten years, putting over $2 trillion in business assets in play, and fewer than one in ten has a formal succession plan (CFIB, 2023).
Impact
Gives profitable Canadian life sciences companies a domestic exit that keeps control, jobs and IP here, and turns retiring owners' equity into patient, locally held capital.
Points of Debate
Most biotechs are pre-revenue and cannot carry buyout debt, so this suits profitable service, manufacturing and device firms rather than drug developers. Employee buyers usually pay less than a foreign strategic acquirer. Deductible contributions and a higher ceiling carry a fiscal cost.

#3D.7 Partnership Terms That Keep Value in Canada

Problem
Not every Canadian company will become an anchor, and many will, and should, partner with or license to foreign pharmaceutical companies. Experienced builders argue this is the pragmatic route, since Canada is unlikely to build its own Genentech. The problem is the terms: core IP is often assigned outright, research moves abroad, and royalties and follow-on value leave with it. Canada has done this since the University of Toronto licensed insulin to Eli Lilly in the 1920s.
Proposal
Define a value-retaining partnership requirement that public programs reward. A qualifying partnership licenses core IP rather than assigning it, so the Canadian entity keeps ownership; retains a royalty or milestone stream in Canada; maintains a Canadian R&D, clinical or manufacturing site for a set period; uses Canadian clinical trial sites; and gives the Canadian company reversion rights if the partner shelves the program, reported through the Exit Registry (3G.1). Companies whose partnerships meet the requirement keep their eligibility for the enhanced SR&ED credit (3E.6), compact and fund-of-funds capital (3D.3, 3C.1) and the IP-retention terms of 3A.3. The requirement rewards good terms; it does not prohibit partnerships that fall short. Regional licensing qualifies: a partner that funds trials and development in exchange for rights in its own region, for example in Asia, while the Canadian company keeps its North American and European rights, meets the requirement.
Precedent
The Israel Innovation Authority's conditions on transferring publicly funded IP abroad (3A.3); AstraZeneca's acquisition of Fusion Pharmaceuticals, which preserved Hamilton operations even as the corporate upside moved abroad (Part 1).
Evidence
A Council of Canadian Innovators study found that 28 of 30 acquired Canadian technology and life sciences firms lost strategic control after acquisition (Part 1). Partnership terms decide whether value stays even when ownership does not.
Impact
Turns the partnership model from a source of leakage into a deliberate strategy: Canada keeps the IP, repatriated revenue such as a royalty stream, jobs and clinical activity, while partners supply the global scale. It answers the most common objection to an anchor-first strategy by making both routes work for Canada.
Points of Debate
Partners may pay less, or walk away, if terms are tighter, which is why the requirement rewards rather than mandates. Small companies have little bargaining power, so public backing through the compact (3D.3) and the growth window (3C.1) matters. Defining a qualifying site and holding period needs care to avoid token commitments.

#3D.8 A Canadian Innovation Box

Problem
SR&ED rewards spending on research, not the income that comes from commercializing it, so nothing in the federal tax system rewards keeping IP, and the profits it earns, in Canada once a product succeeds (Part 1). Testifying to the House Science and Research Committee, the C.D. Howe Institute's Daniel Schwanen described Canada as "a net exporter of ideas" that nonetheless pays more for IP than it earns, and as "better at research than at securing the fruits of this research" (SRSR, 2023).
Proposal
A federal innovation box: a reduced corporate tax rate on income from patents and similar IP developed in Canada and used in a business here. It follows the OECD's modified nexus approach, under which the benefit is proportional to the qualifying R&D done in Canada, so the box rewards IP that is both created and commercialized here and cannot be used simply to park foreign IP. It complements SR&ED (an input credit) and the IP-retention terms of 3A.3.
Precedent
Quebec's Incentive Deduction for the Commercialization of Innovations, which taxes qualifying IP income at an effective provincial rate of 2%, scaled to the share of the underlying R&D done in Quebec (Quebec); the UK Patent Box (10% rate); and similar regimes across Europe, aligned with the OECD nexus rule.
Evidence
The C.D. Howe Institute estimated the federal cost of a patent box at about $500 million a year, and Deloitte has argued the rate should be significantly lower than the regular business rate (SRSR, 2023).
Impact
Rewards the commercialization stage, not only research, and gives companies a tax reason to keep their IP and the profits from it in Canada as they succeed.
Points of Debate
Evidence that patent boxes increase innovation, rather than relocating taxable income, is mixed, and the benefit flows mainly to companies already profitable, which few Canadian biotechs are. The fiscal cost is significant. Design must avoid stacking with SR&ED and the capital gains measures in this package. Many IP practitioners doubt that a patent box does much for life sciences, where profits arrive a decade or more after the patents are filed and the binding constraint is capital, not the tax rate on profits. This is why the module is not in the priority package.

3E. Talent, Lab Space and Clinical Development

Capital alone does not build a company. Scaling firms also need experienced commercial leaders, specialized facilities, and a reason to run their clinical trials here: funding partners who share the risk, an ethics review that does not repeat at every site, and a government that understands the sector. Leadership ambition matters as much as any program. Canada's companies with anchor potential are led by people who have said publicly that they intend to build, not sell: AbCellera's stated aim is a global biotechnology company that can repeatedly discover and commercialize medicines, and Xenon's chief executive has said the company wants to build a fully integrated company (Silcoff, The Globe and Mail, 2026). Policy cannot create that ambition, but it can stop penalizing it.

Where Section 3E sits on the company journey

#3E.1 Scale-Stage Executive Fellowship and Talent Offset

Problem
Canada lacks executives who have scaled companies past $100M in revenue, especially on the commercial side. Canadian start-ups often recruit U.S. chief executives because experienced Canadian ones are scarce or unaffordable, and leadership based in the U.S. tends to pull the company's next financing, and eventually the company, south with it.
Proposal
A federal fellowship plus a five-year commercialization talent tax offset to recruit proven global revenue leaders (CMOs, CROs, CFOs, BD leads) into Canadian growth firms, including repatriating diaspora executives. This module covers recruiting experienced commercial leaders into scale-stage companies. Developing clinical and operating leaders is covered in 3E.7, and the immigration routes for founders and executives in 3E.2.
Precedent
The commercial counterpart to the Global Impact+ research talent initiative.
Evidence
Canadian scaling firms fill 78% of CFO and 69% of CTO roles domestically, but only 43% of CMO and CRO roles (Plant, C.D. Howe Institute, 2023).
Impact
Closes the go-to-market gap that capital alone cannot.
Points of Debate
Subsidizing salaries firms could pay themselves. Salaries supported by the talent offset cannot also be claimed under the commercialization matching credit (3B.4).

#3E.2 Outcome-Linked Founder and Executive Immigration

Problem
The Start-Up Visa closed to new applications on December 31, 2025, with a backlog of about 43,000 cases. IRCC plans a replacement entrepreneur pilot in 2026.
Proposal
Design the replacement pilot with temporary residency on acceptance and permanent residency conditional on jobs, revenue and domestic IP retention. Add a fast route to permanent residence for experienced C-suite and clinical leaders recruited by Canadian life sciences companies, building on the two-week work permit processing the Global Skills Strategy already offers.
Precedent
Outcome-linked founder visas in several OECD countries. The federal Global Skills Strategy, which since 2017 has processed work permits for executive, managerial and professional talent in two weeks (IRCC, 2017).
Evidence
IMI Daily, December 2025.
Impact
Faster founder attraction with accountability.
Points of Debate
Program integrity concerns. An executive fast track may be criticized as favouring a small group.

#3E.3 The Picks-and-Shovels Layer

Problem
Anchor companies depend on CDMOs, GMP manufacturing, wet labs and specialist services, a layer that is thin in Canada. Canada has no dedicated cGMP capacity to scale cell and gene therapies to clinical quantities. The bottleneck is not uniform: asset-centric drug developers run virtually and outsource to CROs and CDMOs, while platform companies, cell and gene therapy developers, biomanufacturers and medical device startups need their own graduation space.
Proposal
Extend the tax treatment in Section 3B to this service layer, and direct federal infrastructure funding to multi-tenant cGMP and wet-lab facilities in designated corridors, prioritizing the company types above.
Precedent
Massachusetts' state-backed life sciences infrastructure investment.
Evidence
Massachusetts had 18 anchor companies against one in British Columbia (Thomas and Maine, 2019). In U.S. Census data, a one-standard-deviation rise in average pay at anchor-industry firms is associated with 21% more spin-offs, and each anchor job supports about 1.3 regional jobs (Gupta, 2020). Both as cited in adMare Institute, 2023.
Impact
The ecosystem that lets anchors form and stay.
Points of Debate
Public capital competing with private real estate.

#3E.4 Venture Tenant Insurance

Problem
Specialized wet-lab build-outs cost $500 to $1,200 per square foot. Commercial landlords cannot justify that for tenants with 18- to 24-month runways, so graduation space does not get built. The gap is acute for platform biotechs, cell and gene therapy developers, biomanufacturers and medtech hardware companies; virtual, asset-centric drug developers can rely on CROs and CDMOs instead (see 3E.3).
Proposal
A mutualized Venture Tenant Insurance pool covering 60% to 70% of rent for 9 to 18 months if a tenant defaults, drawing in private commercial real estate capital. This is market design, not subsidy.
Precedent
CMHC mortgage insurance; EDC credit insurance.
Evidence
McMaster University actuarial study, Venture Tenant Insurance Discussion Paper (v3-3) (2024), an unpublished discussion paper the author has made available for wider sharing; figures in this module rest on it. The author tested the concept with developers and banks: developers were receptive, but banks declined to participate during the funding downturn.
Impact
Private capital builds the space instead of companies building their own.
Points of Debate
Lenders, not landlords, are the hurdle: without bank participation the model does not work. Biotech defaults cluster in funding downturns, so the pool may need a government reinsurance backstop, as CMHC provides for mortgages. Participation may need to be standard in certain programs or facilities to avoid adverse selection, and pricing has limited historical default data to draw on.

#3E.5 Protected Corridors and Medical Isotope Sovereignty

Problem
Upstream strengths, such as isotopes, are not converted into Canadian-owned downstream manufacturing.
Proposal
Designate Toronto, Montreal, Vancouver and Hamilton as protected clusters with aligned tax, capital and regulatory speed; build Canadian-owned radiopharmaceutical manufacturing around isotope supply.
Precedent
U.S. SBIR-linked cluster strategies.
Evidence
McMaster's reactor supplies about 60% of the world's iodine-125; Ontario's $4.6M expansion raises capacity by roughly 300%.
Impact
Captures high-margin finished products, not just raw material.
Points of Debate
Picking winning regions.

#3E.6 Tiered SR&ED Credits for Clinical TrialsPriority 4

Problem
Canada’s historical share of the global clinical trials market has consistently degraded, resulting in lost direct medical investment and delayed domestic patient access.
Proposal
Make clinical trial spending at Canadian sites eligible for SR&ED, for Phase I, II and III trials and for postmarketing Phase IV studies that generate new clinical evidence. Keep the program's existing tiers, and tie the conditions to the IP rather than the owner. Owned here: Canadian-controlled private corporations and eligible Canadian public corporations claim the enhanced 35% refundable credit on their trial spending. Used here: foreign-controlled sponsors claim the basic credit for trials run at Canadian sites, because those trials still give Canadian patients early access to new medicines, train Canadian investigators and rebuild Canada's share of global trials. Safeguard: if IP developed with the enhanced credit is sold or moved offshore within a set period, part of the credit is repaid on a declining scale, using the same substance test as 3A.3 (where headquarters, R&D and staff are, not legal domicile). So that the credit helps during the trial rather than a year later, BDC offers loans secured against refundable credits earned but not yet paid, letting companies fund Phase I and II trials without issuing more voting shares.
Precedent
Australia's R&D Tax Incentive (RDTI), which pays a 43.5% refundable offset to smaller companies, including pre-revenue biotechs, and covers Phase I trial costs. Combined with fast trial start-up, it has made Australia a preferred destination for first-in-human trials: North American biotechs sponsor 42% of Australian Phase I oncology trials (IFP, 2026).
Evidence
Canada's share of global clinical trials dropped from 6% to 4%, representing an annualized opportunity cost of $2.5B in trial spending and roughly 20,000 jobs. The Pharmaceutical and Life Sciences Sector Task Force recommended adjusting SR&ED criteria to stimulate trial investment [Pharmaceutical and Life Sciences Sector Task Force, 2026]. The tiers already exist. Since Bill C-15, the enhanced 35% refundable rate applies to Canadian-controlled private corporations and to eligible Canadian public corporations not controlled by non-residents, on up to $6 million of qualifying spending a year; other corporations claim the basic 15% non-refundable rate (BDO). The eligibility problem is long-standing: Canada's definition of R&D for tax purposes centres on early-stage research and leaves out much later-stage development that other countries' credits cover (Barber and Crelinsten, 2016). Clinical trials are the largest later-stage cost in drug development.
Impact
Brings more global trials to Canadian hospitals, creating clinical research jobs and giving Canadian patients earlier access to new medicines through trial participation.
Points of Debate
The Senate Banking Committee recommended limiting SR&ED to Canadian-controlled companies (Senate BANC, 2026, Recommendation 2). This module shares the goal but keeps the basic credit for foreign-controlled sponsors' Canadian trials, because a blanket exclusion would send trials, and Canadian patients' early access to them, elsewhere. The clawback answers the concern that Canada subsidizes IP that then leaves. A clawback also lowers what a foreign buyer will pay for a Canadian company, so repayment should decline over time and end after a set period. The $6 million annual limit on the enhanced rate is small relative to Phase II and III costs. Phase IV eligibility must exclude studies run mainly for marketing purposes.

#3E.7 A Clinical and Operating Leadership Pipeline

Problem
Capital without experienced operators stalls at the clinic. Canadian companies struggle to find chief medical officers and clinical development leaders, and the same small pool of experienced executives is recycled across boards and companies rather than renewed. Founders from the lab rarely have run a clinical program, and there is no structured route for the next generation of operators to learn by doing.
Proposal
Develop clinical and operating leaders in Canada, in two parts. First, an executive-in-residence program that places seasoned operators (CEOs, chief medical officers, heads of clinical development) inside university and hospital spinouts for 12 to 24 months, co-funded by the program and the venture philanthropy fund (3A.9), extending the advisory entrepreneur-in-residence model universities already run into hands-on placements; it also supplies the operators for pre-seed matchmaking (3A.7). Second, a clinical development leadership track: funded fellowships that place mid-career physicians, scientists and project leaders inside Canadian companies' clinical programs, with structured training in trial design, regulatory strategy and clinical operations. Placements pair experienced executives with emerging ones, so the program renews the talent pool rather than recycling it. A mentorship tax benefit compensates experienced operators who mentor or advise startups in lieu of fees. Recruiting experienced commercial leaders is covered in 3E.1, and immigration routes for executives in 3E.2.
Precedent
UBC's Entrepreneurs in Residence, experienced founders and executives who coach university ventures and reported more than 15,000 hours with ventures in 2020 (UBC Innovation). The International Intellectual Property Forum–Québec (FORPIQ) proposed a tax benefit for entrepreneurial mentors who assist start-ups and SMEs in lieu of payment, as recorded in the Standing Committee on Science and Research's 2023 report on commercializing IP (SRSR, 2023).
Evidence
Clinical leadership is an even narrower pool than the senior commercial roles Canadian firms struggle to fill at home (3E.1), and it is the bottleneck that decides whether a funded company reaches its next clinical milestone.
Impact
Turns capital into executed clinical programs, keeps experienced leadership in Canadian companies, and builds the next generation of operators who will run Canada's anchor companies.
Points of Debate
Placements are costly, and a poorly matched executive can harm a young company; matching and short initial terms reduce the risk. The program must favour mentoring emerging leaders over recycling the same few executives.

#3E.8 Shared-Risk Co-Funding: Companies, Health Charities and Government

Problem
Clinical and translational research in Canada runs in a circular dependence on government grants. Each funder backs projects alone: companies carry trial risk by themselves, health charities fund investigator-led studies that rarely reach the scale of a pivotal trial, and public grants end with no committed partner to carry the work forward. No party has enough at stake in the others' success.
Proposal
Create a three-way co-funding model for investigator-led and early company-sponsored trials in which a company, a health charity and government each contribute one third. Government's third is released only once the other two are committed, and it is awarded competitively through the national platforms (3A.6) to trials that use the single ethics review (3E.9). Charities fund trials in their disease area at three times their own spend; companies gain access to investigator networks and patient communities; public money follows private and charitable conviction instead of carrying the risk alone. Charitable contributions can draw on the foundation and donation measures (3C.5, 3C.6), company spending at Canadian sites qualifies for the SR&ED clinical trial credit (3E.6), and IP and data terms follow the partnership requirement (3D.7). All federal clinical trial funding, including this model, follows a regulatory readiness rule: an award either pays for the Clinical Trial Application work (GMP manufacturing, toxicology and the regulatory dossier) or requires a credible, costed plan for it, rather than assuming it is already done.
Precedent
Brain Canada and the Canada Brain Research Fund: Budget 2024 committed $80 million over four years, matched by Brain Canada with donors from the private, public and charitable sectors, for a total of $160 million in competitively awarded research (Government of Canada, 2024).
Evidence
Matching already moves money in Canada: the Brain Canada match doubles the federal commitment. Under a one-third model each taxpayer dollar brings two others, and every party has money at risk, which aligns all three on choosing trials that can succeed. Canada's share of global clinical trials has fallen from 6% to 4% (3E.6). BioCanRx reports that projects selected in recent federal clinical trial competitions have been delayed because no one had funded the regulatory readiness work needed to file a Clinical Trial Application.
Impact
Breaks the circular grant cycle, gives health charities a lever beyond small grants, and puts more trials, and more enrolled patients, in Canada.
Points of Debate
Three funders can mean slower decisions, so a standard agreement and fixed decision deadlines are needed. Company money can bias which questions get studied; investigators and charities must keep control of trial design and the right to publish all results. Smaller charities may not afford a full third, so pooled charity funds or a lower share for rare diseases may be needed. Charitable funds must serve charitable purposes rather than private benefit, which the CRA registration pathway (3A.9) can help clarify.

#3E.9 A Single Research Ethics Review for Multi-Site Trials

Problem
A multi-centre trial in Canada still typically needs separate research ethics board approvals at each site, repeating the same review and adding months to start-up. That delay makes Canada a slower choice for global sponsors. Ontario has built a streamlined provincial system, but a single national review is only now being set up, and no rule yet requires institutions to rely on one review.
Proposal
Make single review the default in two steps. Step 1, Ontario: institutions that receive provincial research or hospital funding accept the decision of one qualified research ethics board for multi-site trials, on the Clinical Trials Ontario model, with firm review deadlines; local review is limited to site-specific matters such as resources and local context. Step 2, national: provinces sign a reciprocity agreement so one review covers every participating site in Canada, delivered through CanReview, the pan-Canadian single review now being built. Federal clinical trial funding, including the co-funding in 3E.8, goes first to institutions that accept the single review, and review times are published. It pairs with the SR&ED clinical trial credit (3E.6): the tax credit attracts sponsors, and fast start-up keeps them.
Precedent
Clinical Trials Ontario's streamlined research ethics review, in which one qualified board oversees a study across multiple Ontario sites; its CTO Stream platform has supported single ethics review since 2015 and managed more than 2,500 multi-site studies (Clinical Trials Ontario). CanReview, selected by the Accelerating Clinical Trials (ACT) Consortium to build a single pan-Canadian review with firm timelines, launched in December 2025 (BIOTECanada, 2025). In the United States, NIH has required a single IRB for funded multi-site studies since 2018, and the revised Common Rule has required one for federally funded cooperative research since 2020 (NIH). Australia's Clinical Trial Notification (CTN) scheme goes further: the sponsor notifies the regulator rather than seeking approval, and the ethics committee reviews the science, safety and dosing. Trials there can begin 6 to 12 months earlier than in the United States (IFP, 2026).
Evidence
Ontario's experience with more than 2,500 multi-site studies shows that single review works at scale, and both Innovative Medicines Canada and BIOTECanada have publicly backed CanReview. What is missing is the requirement to use it.
Impact
Faster trial start-up, more global trials placed in Canada, and wider access for patients at community, rural and remote sites.
Points of Debate
Institutions remain legally responsible for research at their sites and may resist relying on another board, so liability and accountability terms must be clear. Indigenous communities' own review and data governance must be respected, not overridden. Ethics review sits with provinces and institutions, so the national step depends on provincial agreement. Boards must stay independent of sponsors as industry pushes for speed. Health Canada already reviews Clinical Trial Applications against a 30-day default. A notification route for early-phase trials, on the Australian model, would go further, but only works if ethics boards have the capacity and expertise to carry the scientific review.

#3E.10 Industry Expertise Inside Government

Problem
The departments that design and run life sciences programs, including ISED, Health Canada and PHAC, have few staff who have built a company, run a clinical trial or managed a fund. Policy is written by capable generalists, and programs can misread how capital, trials and regulation work in practice.
Proposal
Create a two-way exchange of one- to two-year placements. Industry PhDs and MBAs, scientists, clinical operators and investors join ISED, Health Canada, PHAC and the coordinating authority (Part 4) to work on program and policy design; public servants spend time inside companies, funds and hospitals. Run it through an expanded Interchange Canada with a dedicated life sciences cohort, salary top-ups where pay gaps would block recruitment, and strict conflict-of-interest rules: recusal from any decision affecting the home employer and a cooling-off period on return.
Precedent
Interchange Canada, the Treasury Board program for exchanges into and out of the federal public service, which the Public Policy Forum urged government to promote and use far more widely (PPF, 2019); the Mitacs Canadian Science Policy Fellowship, which places PhD holders in federal and provincial departments for one year, 22 in its 2018–19 cohort (Mitacs, 2018); the U.S. Intergovernmental Personnel Act mobility program, through which agencies such as NIH take staff on assignment from universities and non-profits.
Evidence
The Public Policy Forum recommended building the structures and incentives needed for much wider uptake of Interchange Canada, including a critical mass of exchanges in fast-moving technical fields. The mechanisms exist; they are not used at the scale or in the fields this package needs.
Impact
Programs designed by people who understand how companies, trials and investors work; public servants who understand the sector they fund and regulate; and an industry that understands government.
Points of Debate
Placements raise the risk of regulatory capture, particularly at Health Canada, so industry placements there should focus on policy and program design, not product decisions. Public pay scales make senior industry talent hard to attract. Short placements can end before they have impact, which argues for two-year terms in key roles.

3F. The First Customer

Canada's public health system is the natural first customer for Canadian health innovation, yet procurement rewards the lowest upfront price rather than long-term value and rarely buys from domestic firms. Sections 3F and 3G address the health system adoption gap: the years between regulatory approval and patient access. Innovation here includes process as well as product: a better way to use the beds, staff and equipment the system already has is innovation too, and it often pays for itself. How care is delivered also shapes who can buy. Care is concentrated in hospitals, so a small number of large institutions, each with its own procurement process, decide what is adopted, and routine procedures queue behind hospital capacity. Several European systems, Germany's among them, deliver much routine specialist care outside hospitals through publicly insured clinics and office-based physicians. Publicly funded community clinics in Canada would add more, smaller buyers able to adopt quickly, so reforms to how care is delivered and to how the system buys should be designed together. The gap is not money: Canada spends well above the OECD average on health, but in the Commonwealth Fund's 2023 survey of 10 high-income countries, Canadians were the least likely to get a same- or next-day appointment (CIHI, 2024). Process and technology that make better use of existing capacity are where the return lies.

Where Section 3F sits on the company journey

#3F.1 Total Economic Return Procurement ScoringPriority 7

Problem
Canadian healthcare procurement is predominantly optimized for cost-minimization. By evaluating bids heavily on the lowest upfront unit price, single-payer provincial health authorities lock out domestic innovators whose products offer superior long-term clinical or economic value, despite value-based procurement work such as the CAN Health Network's. This forces Canadian life sciences companies to secure their first reference contracts abroad, signalling to international markets that their own domestic system lacks confidence in the technology.
Proposal
Implement a standardized Total Economic Return (TER) Procurement Model across all provincial health authorities and Group Purchasing Organizations (GPOs). Under this framework, contract adjudication must transition from a lowest-cost evaluation to a mandatory 100-point balanced scorecard. Bids are scored on a combination of clinical performance, direct acquisition cost, and domestic economic yield. To drive cross-jurisdictional compliance without violating provincial jurisdiction over healthcare delivery, the federal government offers dedicated new funding to provinces that adopt the TER framework, delivered through bilateral agreements, as it has done for drugs for rare diseases, rather than attaching conditions to existing Canada Health Transfer payments, which provinces would resist. Once the model is proven, adoption can be built into performance-based escalators in future health transfer renewals. Enabling step: scoring on long-term value requires hospitals to know what care costs and what it achieves. As a precondition for TER scoring, provinces adopt patient-level costing and standard outcome measurement, using the outcome sets of the International Consortium for Health Outcomes Measurement (ICHOM) within the value-based health care framework of Porter and Teisberg. No new agency is created. Provincial health authorities and existing GPOs apply the scorecard within their current procurement budgets; the permanent coordinating authority (Part 4) maintains one common scorecard so suppliers face the same rules in every province, and federal funding flows through the bilateral agreements. Qualification should travel: a Canadian product that qualifies through one province's procurement or listing process is fast-tracked in the others through mutual recognition, building on current federal and provincial work to remove internal trade barriers, so a Canadian firm does not have to win thirteen separate markets one at a time.
Precedent
The European Union’s Most Economically Advantageous Tender (MEAT) criteria under the 2014 Public Procurement Directive. Ontario hospitals already report patient-level case costs through the Ontario Case Costing Initiative (Ontario, OCCI), and ICHOM publishes standard outcome sets for major conditions (ICHOM).
Evidence
Part 1 shows that legacy "buy local" templates are deeply flawed, frequently classifying foreign multinational distribution warehouses as local vendors based entirely on logistics footprints. Simultaneously, Canadian companies are shut out of domestic hospital networks, accelerating capital and asset leakage. The Senate Banking Committee called for a strategic procurement framework that uses federal purchasing power to grow Canadian-controlled SMEs, and heard that the minimum project thresholds in the new Buy Canadian Policy exclude many early-stage, venture-backed firms (Senate BANC, 2026, Recommendation 1).
Impact
Transforms the massive buying power of the public healthcare system into an active commercialization engine for homegrown scale, allowing Canadian firms to secure critical domestic reference contracts.
Points of Debate
Trade compliance under international agreements such as CETA, the CFTA and the WTO Agreement on Government Procurement (GPA). Trading partners and foreign bidders could argue that awarding points for domestic IP and manufacturing is a buy-domestic preference those agreements restrict. The Mitigation below limits where those criteria apply. Provinces will resist federal conditions attached to existing health transfers. Dedicated new money through bilateral agreements, as with the National Strategy for Drugs for Rare Diseases, is more workable but costs more, and the agreements must be long enough for provinces to change procurement practice.
Mitigation
Categories 3, 4, and 5 apply only to contracts below the CETA and WTO-GPA thresholds for sub-central entities, or to procurements by non-covered entities. Because the operational scorecard establishes a baseline evaluation floor of $250,000, these explicit industrial anchoring metrics apply within the narrow band of transactions falling between $250,000 and the international sub-central treaty threshold limits. For all procurements valued above those international agreement thresholds, implementing these criteria would necessitate targeted trade carve-outs negotiated at the interprovincial or international level.

Total Economic Return (TER) Illustrative Scoring Metrics

To establish a clear structural framework, public healthcare tenders exceeding an illustrative floor of $250,000 for pharmaceuticals, medical devices, and digital health tools will be evaluated using the following balanced 100-Point Scorecard:

  1. Upfront Acquisition Cost (30 Points Maximum): Maintained to protect public fiscal prudence, avoiding a total disregard for baseline pricing. The lowest compliant bid receives the full 30 points. All competing bids are awarded points on a declining linear scale relative to the lowest bid using the formula: Points = 30 × (Lowest Bid Price / Competing Bid Price).
  2. Systemic Clinical Net Yield (30 Points Maximum): Measures the total economic footprint of the technology across the healthcare delivery continuum rather than evaluating the unit in isolation. Evaluated based on verifiably documented or clinically modelled outcomes over a 24-month patient horizon:
  1. Domestic R&D and IP Anchor (20 Points Maximum - Subject to Trade Gating): Rewards the continuous generation and retention of high-value knowledge wealth within Canada, counteracting the patent leakage documented in the IRPP data. Points are awarded based on an illustrative 15% corporate R&D reinvestment threshold and domestic patent control:
  1. Advanced Human Capital & Manufacturing (10 Points Maximum - Subject to Trade Gating): Incentivizes vendors to establish high-paying technical jobs and industrial infrastructure domestically. Evaluated by the physical and human resource allocation within Canada:
  1. Supply Chain Resilience & Security (10 Points Maximum - Subject to Trade Gating): Mitigates the systemic healthcare vulnerabilities exposed during international supply chain disruptions. Points are awarded based on proximity and an illustrative six-month physical stock allocation:

#3F.2 Adopter-Side Budgets

Problem
The hospital department that buys an innovation rarely captures the savings, which land elsewhere.
Proposal
Give hospital CFOs flexible innovation and workflow-change budget lines through the CAN Health Network and CDAP.
Precedent
Germany's DiGA fast track: a three-month assessment, then national reimbursement.
Evidence
BfArM DiGA guide.
Impact
Adoption becomes affordable at the point of decision.
Points of Debate
New spending at a time of budget pressure.

#3F.3 Procurement Risk Pooling

Problem
A failed domestic pilot is a career risk for a hospital CFO; a failed foreign purchase is not.
Proposal
A federal-provincial fund that absorbs the risk of a mandated domestic purchase that underperforms.
Precedent
Innovation procurement risk-sharing in the EU.
Evidence
Risk asymmetry drives incumbent bias.
Impact
Removes the personal penalty for trying Canadian.
Points of Debate
Moral hazard.

#3F.4 First-Customer Set-Aside

Problem
Scale-stage firms lack a reference customer at home.
Proposal
Reserve a share of eligible federal, defence and health procurement for Canadian scale-stage firms, with sole-source follow-on contracts. Firms that complete Phase II of the Canadian SBIR (3A.5) qualify for these follow-on contracts.
Precedent
U.S. SBIR, which sets aside about 3% of large agencies' external R&D budgets and allows Phase III sole-source contracts.
Evidence
SBA program data.
Impact
Guaranteed first revenue and a reference.
Points of Debate
Trade obligations; quality risk.

#3F.5 Advance Purchase Contracts

Problem
Canada funds health security products with piecemeal project grants, then buys finished products from abroad: the export-and-buy-back loop.
Proposal
Government as early strategic buyer: BARDA-style advance purchase contracts that guarantee pre-committed orders for domestic dual-use health and biodefence products.
Precedent
U.S. BARDA; COVID-era advance purchase agreements.
Evidence
The Pharmaceutical and Life Sciences Sector Task Force (2026) recommends procurement incentives to anchor domestic production.
Impact
Guaranteed demand that lets domestic capacity form and stay.
Points of Debate
Paying for capacity that may sit idle.

#3F.6 Separating Public Financing from Service Delivery

Problem
Single-provider delivery limits competition and surgical capacity.
Proposal
Keep 100% public, single-payer financing while opening delivery to accredited public and private providers paid through risk-adjusted capitation.
Precedent
Sweden.
Evidence
Labrie, Y. (2026). Beyond the Public-Private Divide: What Sweden Can Teach Canada. Fraser Institute, September 2026. The study reports that Sweden expanded surgical capacity and shortened waits without queue-jumping or loss of equity.
Impact
More delivery capacity without user fees.
Points of Debate
Highly contested. Critics, including the Canadian Centre for Policy Alternatives, argue private delivery draws staff from the public system and raises costs; the Canada Health Act limits some models; Swedish results may not transfer to Canada's provincial structure.

#3F.7 A Canadian ARPA-H: Provinces as First Customers, Returns on the Books

Problem
Canada funds health innovation through pieces that each cover part of the chain, such as the National Research Council's Challenge programs, the CAN Health Network and adMare BioInnovations. No one books what an innovation returns to government. Health spending is treated as a cost to contain, so the savings an innovation creates downstream never reach the ledger of the person who has to say yes. Meanwhile, all-Canadian syndicates supply more than 70% of the money in rounds under $5 million but only 12.7% in rounds above $50 million: Canadians fund the risk, and others own the outcome.
Proposal
Create an arm's-length, not-for-profit health innovation agency built on the Grand Challenges Canada design rather than a copy of the U.S. model. Provinces name health-system challenges and act as first customers. The agency runs a venture-style funnel of many small bets, provides bespoke grant, debt and equity capital, shapes demand through procurement, and measures the fiscal return of each innovation and reports it to finance ministries, with federal-provincial cost sharing based on modelled shares of that return. To make the first-customer commitment credible, pair it with procurement risk pooling (3F.3), so the buying institution does not carry the downside alone, and score purchases using Total Economic Return (3F.1). The agency has one named, accountable owner.
Precedent
Grand Challenges Canada, an arm's-length funder created with $50 million in the 2008 federal budget, which has supported more than 1,600 innovations in more than 100 countries, but only within Canada's international development envelope; the U.S. Advanced Research Projects Agency for Health (ARPA-H).
Evidence
Peter Singer models a public cost of about $9 billion over 25 years, including $100 million a year for the agency and its programs, returning about $68 billion to government over the same period (about half to the provinces) and $30 to $40 billion in value to firms. He estimates that raising Canada's retained share of large rounds from 12.7% to 40% would triple the value held in Canada (Singer, 2026). These are his own modelled estimates, with the method published; he notes the model should be tested.
Impact
Gives provinces a reason to buy and companies a reason to stay, and creates the missing ledger: a measured fiscal return that finance ministries can count. It complements the capital measures rather than replacing them, since first-customer revenue alone does not fill $50 million-plus rounds.
Points of Debate
The return figures are modelled and assume finance ministries will book innovation returns, which they have not done before. Naming provinces as first customers puts the decision inside the procurement system where blame-minimization lives, which is why risk pooling is part of the design. A new agency could add to fragmentation unless it absorbs or coordinates existing programs. The author discloses that he co-founded and sits on the board of Grand Challenges Canada, which informs the design he recommends.

3G. Patient Access and Reimbursement

Regulatory approval is not access. Canadian-developed products too often reach patients abroad first, or never complete the sequential federal and provincial review path at home.

Where Section 3G sits on the company journey

#3G.1 Approved-but-Not-Pursued Exit RegistryPriority 8

Problem
The Canadian market access pipeline is opaque. Because health system reviews run sequentially across isolated federal and provincial silos, therapies frequently stall or are quietly withdrawn from commercial consideration. Because these decisions happen in private corporate boardrooms without an aggregated public record, policymakers lack empirical visibility into exactly which regulatory or economic friction points are causing global life sciences firms to bypass Canada.
Proposal
Enact federal legislation creating a mandatory public Approved-but-Not-Pursued (ANP) Exit Registry. Under this statutory framework, any corporate sponsor that receives a positive Health Canada regulatory approval covering safety, efficacy, and quality, but fails to submit for public reimbursement review within 12 months, must file a public disclosure report. The filing must set out the specific institutional, structural, or economic bottlenecks (such as pCPA price negotiation standstills or sequential regulatory blockages) that triggered the commercial exit. The Exit Registry becomes the approval-to-reimbursement stage of the lab-to-ownership registry run by the permanent coordinating authority (Part 4). Repatriation provision: the registry also records Canadian-origin life sciences assets held by foreign owners. Publicly funded IP, and partnerships that meet the value-retaining requirement (3D.7), carry a right of first notice: when a foreign owner moves to sell or divest a Canadian-origin asset, Canadian buyers receive early notice and a fixed window to bid, with access to cornerstone financing through the domestic capital compact (3D.3) and the Cornerstone IPO Fund (3D.2). The filing is deliberately light: a short standard form on which the sponsor selects its reasons from a set list, with an optional note, and no confidential pricing information is required. Medicines that are not required to go through Canada's Drug Agency or INESSS review, such as some used only in specialized settings, are recorded by category and do not require a report. A second track needs no sponsor disclosure. Each year, Health Canada publishes the new medicines approved by the U.S. Food and Drug Administration or the European Medicines Agency in the previous two years that have not been filed in Canada, and invites, but does not require, their sponsors to give a reason. Together the two tracks show the whole gap: medicines never filed here, and medicines approved here but never submitted for public reimbursement.
Precedent
Health Canada’s existing Drug Shortages and Discontinuances database, expanded from a clinical shortage monitor to a structural market-access diagnostic tool.
Evidence
The Core Evidence confirms that only 48.5% of all approved drugs are submitted for public reimbursement review, exposing a massive structural drop-off that occurs right after regulatory approval [Pharmaceutical Technology / GlobalData, 2026]. Recent examples show the risk: after Health Canada approved Novartis's Vanrafia in July 2026, the company declined within weeks to seek public reimbursement, citing the current access environment. U.S. most-favoured-nation pricing policy, which links U.S. prices to those in other wealthy countries, may also discourage launches in lower-priced markets such as Canada; the two pressures are hard to separate, and this registry would show which one drives decisions like this. The only longitudinal count of Canadian public life sciences companies, tracking survivals, acquisitions, failures and repurposed shells from 2007 to 2016, was compiled privately by Tony Pullen, a former healthcare investment banker (Pullen, 2013, 2015, 2017). A registry would make this record official and continuous. Only 18% of new drugs launched globally are available through Canadian public drug plans (Hamelin, 2026). Today no public source shows how much of the other 82% was never filed in Canada and how much was filed but never reimbursed.
Impact
Provides policymakers and the public with immediate data regarding the failure points in the access pipeline, turning legacy opacity into measurable legislative accountability.
Points of Debate
Industry concerns regarding the forced disclosure of proprietary commercial strategies. Mitigation: The registry uses standardized categorical checkboxes and high-level structural reasonings rather than requiring the publication of explicit, confidential transaction pricing or trade secrets. A notice right is not a veto: foreign owners can still sell to the best bidder after the window closes, and the window must be short so it does not depress the price or delay deals. If reporting becomes burdensome, it could become one more reason for companies not to launch in Canada; the form must stay short. Health Canada cannot require a company to file a medicine in Canada, so the not-filed list can only invite reasons. Health Canada also does not disclose submissions under review, so the list must allow for medicines that are filed but not yet approved.

#3G.2 A Reimbursement Pathway for Canadian-Developed Diagnostics

Problem
Canadian-developed diagnostics reach patients abroad years before they are funded at home, and coverage is decided province by province.
Proposal
A national pathway that fast-tracks Canadian-developed diagnostics already in clinical use in peer systems, so one province's approval can extend across Canada. This module covers stand-alone diagnostics; tests that a specific medicine depends on are covered in 3G.6.
Precedent
Germany's DiGA fast track (3F.2); Australia's MSAC process.
Evidence
epiSign, developed at London Health Sciences Centre, was used clinically in the U.S., Europe and Australia before Ontario recognized episignature testing as reimbursable in late 2025 (TechAlliance).
Impact
Canadian patients get Canadian inventions.
Points of Debate
Provincial jurisdiction over lab funding.

#3G.3 Parallel Review and Early Negotiation

Problem
Health Canada, Canada's Drug Agency and pCPA work in sequence, adding years. The accelerated pathways that exist are almost entirely built around oncology, leaving rare disease and other high-need files on the slow track.
Proposal
Concurrent reviews, scaled pCPA early negotiation, and eligibility for accelerated pathways (such as pCPA's Early Negotiation Process and Ontario's FAST pilot) extended to all Health Canada Priority Review files.
Precedent
Singapore's joint pricing and adoption negotiation through one national counterparty; pCPA's Early Negotiation Process for Project Orbis cancer drugs (October 2025), a working prototype of parallel review.
Evidence
Existing pathways cover about 19% of approved files (1% TLR-pTAP, 18% FAST and Orbis). Adding non-Orbis Priority Review files (about 10%) would raise eligibility to about 29%. TLR-pTAP has processed three products in three years (Lau, Mitha and Wills, Current Oncology, 2026; 33: 517; 20Sense Report 36). FAST is an Ontario program: it speeds cancer drug funding in Ontario only, after review by Canada's Drug Agency and pCPA negotiation, so national coverage of accelerated pathways is lower than these figures suggest.
Impact
Faster access, a stronger launch case for Canada, and equity for non-oncology patients.
Points of Debate
Agency capacity and budget impact for public plans.

#3G.4 Patient and Societal Value in Drug Assessments

Problem
Patients already have a voice: Canada's Drug Agency invites patient and clinician group input on every drug review. The gap is in the numbers. The economic evaluation behind each recommendation takes the perspective of the publicly funded health-care payer, so costs and benefits outside the health system, such as caregiver time and the ability to work, are left out of the main analysis (CADTH, 2017).
Proposal
Ensure that patient, caregiver, clinician and societal perspectives, such as caregiver burden, ability to work and unmet need, are formally counted in pan-Canadian value assessments alongside health-system costs. This is a change in whose values count, not a proposal to adopt multiple-criteria decision analysis.
Precedent
Broader value frameworks in several European HTA bodies.
Evidence
Only 18% of new drugs launched globally are available through Canadian public drug plans (Hamelin, 2026), and Canadians wait longer for public access to new medicines than anywhere else in the G7 (Hamelin, 2026).
Impact
Fewer launches skipped.
Points of Debate
Higher prices for public plans.

#3G.5 Regulatory Reliance

Problem
Duplicate reviews delay launches that peer regulators have already approved.
Proposal
Accelerated Canadian authorization and listing eligibility when a trusted regulator (UK, Australia, Switzerland, Singapore) has approved, with Health Canada retaining final authority. Extend the same reliance to medical devices and surgical technologies authorized by the U.S. FDA or certified under the EU Medical Device Regulation, so that technologies already in use abroad, sometimes with donors ready to pay for the equipment and first procedures, are not held for more than a year by a separate Canadian review.
Precedent
The Access Consortium; Swiss and Israeli reliance pathways.
Evidence
Reliance attracts launches and trials.
Impact
Faster approvals and earlier launches.
Points of Debate
A stronger version, automatic recognition of a trusted regulator's approval, is contested mainly on sovereignty grounds. Safety is a weak argument for re-reviewing medicines already in wide use in large populations. This blueprint recommends accelerated reliance first, with automatic recognition for such medicines as a next step to consider.

#3G.6 Co-Dependent Technologies

Problem
Assessment is not the gap: since 2017, Canada's Drug Agency has required sponsors to include the clinical and economic considerations of companion diagnostics in their reimbursement review applications, and since 2024 its reviews have included a dedicated testing procedure assessment (CDA-AMC, 2026). Funding is. The drug and the test are paid for through separate channels, with public drug plans covering the medicine and provincial laboratory budgets covering the test, so a drug can be listed before the test it depends on is funded. The agency's own criteria recognize tests that are not publicly funded in any province, or are funded inconsistently across and within provinces.
Proposal
Coordinated funding decisions for co-dependent technologies, so that when a precision medicine is listed, the test it depends on is funded on the same timeline. Unlike 3G.2, which covers stand-alone Canadian-developed diagnostics, this module covers companion tests that a specific medicine depends on.
Precedent
Australia's MSAC and PBAC co-dependent framework.
Evidence
PBAC Product Type 4 guidelines.
Impact
Precision medicines reach patients with their tests.
Points of Debate
Coordination across jurisdictions that fund drugs and labs separately.

3H. Sovereignty, Data and Supply Chain

COVID-19 showed that health supply is national security.

Where Section 3H sits on the company journey

#3H.1 Health Capability as Defence-Related Spending

Problem
Health budgets are rationed annually (the tyranny of the present), so long-horizon capacity never gets funded. Canada imports most of its medicines, and API supply is concentrated in China and India.
Proposal
Treat biomanufacturing, medical countermeasures and diagnostic platforms as dual-use national defence assets, eligible for multi-year defence-related funding, with STEMCELL Technologies as the domestic anchor exemplar.
Precedent
Canada's new $267M Medical Countermeasures Laboratory in Winnipeg, due in 2033 (announcement); U.S. defence-health manufacturing programs.
Evidence
NATO confirmed Canada reached 2% of GDP on defence in 2025. At the 2025 Hague summit, allies committed to 5% by 2035: 3.5% for core defence and up to 1.5% for defence- and security-related spending, including civil preparedness, resilience, innovation and the defence industrial base (Global News; CP via National Newswatch). Drug imports rose from 74% to 93% of expenditures in a decade; Health Canada's Critical and Vulnerable Drug List covers about 160 ingredients.
Impact
The 1.5% resilience envelope gives health capacity access to long-horizon budgets.
Points of Debate
Whether health spending will count under NATO's definitions; competition with ports, minerals and telecom for the same envelope.

#3H.2 A Statutory Duty to Share Health Data, Built for Research and Trials

Problem
Without accessible Canadian data there are no Canadian trials, AI or real-world evidence, so Canadian innovation cannot scale. Health information laws permit appropriate data sharing but do not require it, so in practice sharing is voluntary. The penalties are one-sided: Alberta's Health Information Act, for example, sets fines of up to $200,000 for individuals and $1 million for organizations for privacy breaches, while withholding health data that delays care or stalls research, a form of health-data-related harm to patients, carries no penalty. A company that needs data from several hospitals must negotiate with each data holder separately, research requests disappear into processes no one measures, and records can be stranded when a vendor contract ends.
Proposal
A statutory designated health data authority with a legal duty to share appropriate health data, not only clinical records but the demographic and operational data that care and research rely on, for primary and secondary uses. The duty applies across the custodians within each jurisdiction's health system and between jurisdictions. It is reconciled with distinctions-based Indigenous health data sovereignty for First Nations, Inuit and Métis peoples, including OCAP® for First Nations and the CARE principles, through Indigenous data custodians accountable to Indigenous governance structures rather than federal, provincial and territorial ones. The duty is built for commercialization as well as care, in five parts. Duty to share, with protection: data holders must share for care and for secondary uses including research and innovation, with legal protection for decisions made in good faith, and unreasonable blocking is treated as non-compliance, following published principles for licensing health data (INOVAIT). Published access numbers: data holders report accepted and refused research requests and processing times, and research ethics review and statutory data permissions are aligned so they work together rather than against each other, alongside the single ethics review (3E.9). Accredited intermediaries: data holders can delegate defined access decisions to accredited third parties operating under standard policies and audits, the practical route to the multi-site data that Canadian AI and trial companies need. Vendor obligations: IT vendors must retain data and plan its transfer, subject to IP and security safeguards, so records are not stranded when a contract ends. Model provincial law: a model Health Information Act that each province adopts, aligned with the pan-Canadian Health Data Charter and the Pan-Canadian Interoperability Roadmap, and rewarded through the opt-in compact (3H.3). Indigenous data sovereignty runs through every part: First Nations, Inuit and Métis governments and organizations share decision-making authority, individuals and communities keep the right to limit disclosure of their own data, and intermediaries include Indigenous representation and oversight where relevant and cannot override community-specific data rules.
Precedent
The European Health Data Space; Singapore's HEALIX platform. Networked Health-BC's recommendations for British Columbia's new health information legislation set out each of these measures, including a duty to share with good-faith liability protection, public reporting on research access, accredited intermediaries, vendor retention duties and alignment across provinces (Networked Health-BC, 2026). Federally, Bill S-5, the Connected Care for Canadians Act, introduced in February 2026, would require common interoperability standards and prohibit data blocking, but would apply only in provinces and territories without substantially similar legislation (Health Canada, 2026). It is also aimed at technology vendors: custodians, the providers who hold the data, would have no duty to share under it, a significant limitation (Networked Health, Bill S-5 policy brief). A model provincial act gives provinces a ready way to meet that test on their own terms and to add the custodian duty S-5 lacks. INOVAIT has published principles for licensing health data that can guide the duty's design (INOVAIT).
Evidence
Affleck, E., HealthcarePapers 21(4), and the Networked Health report. Networked Health's reports on the health information acts of British Columbia and Alberta reach the same conclusions; Disconnected Care assessed Alberta's act against its accountabilities to the Canada Health Act and the Health Data Charter and recommended moving from a custodian model to data stewardship (Tam, Affleck et al., 2025), and Data Disarray examines the wider problem (Networked Health). Only 29% of primary care providers in Canada share patient information electronically outside their practice (Health Canada, 2026). Birch estimates Canadian personal data flowing to Alphabet alone is worth about US$27.2B a year (CIGI, 2026).
Impact
Enables Canadian trials, AI and real-world evidence, and safer care, and gives companies a predictable route to multi-site data at home rather than abroad.
Points of Debate
Privacy, and unclear jurisdiction: health data is not mentioned in the Constitution or the Canada Health Act, so authority over it is unsettled, although provincial health information acts assume oversight (Networked Health, Data Disarray). Good-faith protection must not weaken accountability for real privacy breaches. Accredited intermediaries concentrate risk and need strong audit. Vendor duties must respect IP and security. Provinces may not adopt a model law; Québec does not subscribe to the Health Data Charter, and some jurisdictions that endorse it have done little to act on it. Many communities, particularly Indigenous peoples, have justified concerns about past data misuse; co-governance takes time and must not be bypassed for speed.

#3H.3 Opt-in Health Management Compact

Problem
Federal mandates trigger provincial jurisdictional pushback.
Proposal
Provinces that opt in get predictable long-term funding in exchange for record portability, interoperability and public outcome dashboards, published weekly. Adopting the model health information act (3H.2) counts toward the compact.
Precedent
Adapted from Richard Worzel, Any Minute Now, August 2026.
Evidence
Sections 91 and 92 limit direct federal mandates.
Impact
Turns a constitutional obstacle into an incentive.
Points of Debate
Provinces may decline.

#3H.4 Drug Supply Monitoring and Domestic Production

Problem
Since 2017, drug manufacturers must report actual and anticipated shortages to Health Canada, which gives early warning of some shortages. But reporting depends on each company's own forecasts, and vulnerabilities further up the supply chain, such as reliance on a single foreign source of an active ingredient, are not tracked systematically.
Proposal
Fund a national drug supply observatory as an evidence hub tracking real-time shortages and API vulnerabilities, and target domestic manufacturing at Critical and Vulnerable Drug List items.
Precedent
EU critical medicines list and stockpiling.
Evidence
Researchers led by Dr. Mina Tadrous (University of Toronto) are developing a national at-risk medicine list that weighs both supply-chain and clinical risk (Canada's Drug Agency).
Impact
Early warning and targeted resilience.
Points of Debate
Domestic production of low-margin generics needs ongoing support.

#3H.5 Protecting Domestic Digital Health Infrastructure

Problem
Canadian platforms are displaced by foreign vendors even where no capability gap exists.
Proposal
Data-hosting and procurement rules that weigh sovereignty, including exposure under the U.S. CLOUD Act.
Precedent
EU data sovereignty requirements.
Evidence
McGill's Opal portal was withdrawn in favour of Epic, displacing about 7,000 cancer patients' direct record access.
Impact
Keeps domestic infrastructure and data under Canadian control.
Points of Debate
Cost of replacing established systems. The CLOUD Act's reach is real but not unlimited: requests go through U.S. legal process, providers can and do challenge them, and the Act allows agreements with other countries. The risk is exposure, not automatic access, and rules should be sized to that.

#3H.6 Measuring Translation: Readiness Levels and Life Sciences as an Industry

Problem
Canada cannot see where its life sciences investments stall. The Canadian Research and Development Classification (CRDC) does not separate translational and preclinical work from basic research, and life sciences workers are spread across several industry codes, so the sector's size and the return on public research spending cannot be measured. Without that data, report cards, registries and renewal decisions rest on anecdote.
Proposal
Statistics Canada adds Technology Readiness Levels (TRLs) to the CRDC as a cross-cutting dimension, names translational and preclinical activity within applied research and experimental development, and creates a classification that counts life sciences as an industrial sector as well as a health one, as Australia does. Federal funders tag each award with its readiness level at the start and end. The data feed the lab-to-ownership registry (Part 4), the commercialization-office report cards (3A.4), the Exit Registry (3G.1) and performance-based renewal of national platforms (3A.6). Add an outcome metric alongside research intensity: the annual revenue of R&D-intensive life sciences firms as a share of GDP, compiled by Statistics Canada by linking R&D survey data with tax-filed revenue. Spending on research measures effort; this measures what the sector earns.
Precedent
Australia and New Zealand's research classification (ANZSRC 2020) lists human pharmaceutical products as a socio-economic objective under its Manufacturing division (MBIE); readiness levels are already used by Horizon Europe and by Canadian innovation programs to stage funding.
Evidence
BioCanRx's submission to Statistics Canada's CRDC consultation (September 2025) set out these changes. Statistics Canada's consultation report records a proposal to add translational research to the life sciences division, with the next version, CRDC 2026, scheduled for release in December 2026 (Statistics Canada). The consultation remains open through 2027, so these changes can be made in the next revision. Market classifications distort the picture too. In 2017, cannabis producers were grouped with life sciences in Canadian index and exchange categories: half of the TSX Venture 50's “Cleantech and Life Science” performers were marijuana producers, and more than 20 public cannabis companies were together worth more than the remaining 74 conventional life sciences companies. No Canadian index then measured the sector, because most companies were too small to be included (Pullen, 2017). The Senate Banking Committee likewise recommended that federal business investment programs measure value creation, such as new equity investment, sales and exports, not only jobs (Senate BANC, 2026, Recommendation 1). Barber and Crelinsten showed why spending is the wrong yardstick. Across all sectors, firms spending 3% to 50% of revenue and at least $3 million a year on R&D were only 1.33% of Canada's R&D performers in 2006 but did 38% of industrial R&D; their revenue fell from 8.6% of GDP in 2001 to 5.5% in 2006, and the revenue of R&D leaders on Canada's Top 100 corporate R&D spenders list fell from 7.9% of GDP in 1999 to 4.3% in 2014, much of it the collapse of Nortel. The number of firms doing R&D rose, while average revenue per firm stayed flat (Barber and Crelinsten, 2016).
Impact
Makes progress from lab to market measurable, lets Canada compare itself with peers, and gives the accountability measures in this package data they can rely on.
Points of Debate
Classification changes break historical time series. Readiness levels were built for engineering and fit drug development imperfectly, so a life sciences version may be needed. Tagging awards adds a small reporting burden for researchers and funders.

Part 4: Implementation

An executive-led, transitional Implementation Task Force—chartered with a direct Cabinet mandate and a dedicated operational budget—will execute the rollout across four phases. Moving beyond legacy voluntary coordination bodies that frequently collapse under real macroeconomic shocks, this task force is structured to launch immediate, high-priority legislative vehicles while managing downstream measures on a realistic operational timeline. The package leads with federal measures for a practical reason: provincial tax systems, Quebec's included, generally harmonize with federal changes, so a federal move sets the floor for all ten provinces. These phases mark when each step starts, not when it is finished. Budgets and legislation take time, which is why the first six months use only steps that need no new legislation and why the Task Force has a direct Cabinet mandate. Measures that need the provinces and territories will take longer and begin with willing jurisdictions.

Membership reaches beyond the health system. Alongside life sciences, health system and government members, the Task Force includes operators from other sectors, such as procurement, supply chain and logistics leaders who have run large systems to a budget. It is held to one headline outcome metric, set in its charter and reported at every milestone: the share of federally funded discoveries that reach patients through companies still owned in Canada, as tracked by the registry below.

To ensure complete accountability, the Task Force is mandated to publish transparent progress dashboards against each phase and report directly to Parliament at the 6-month and 12-month marks.

After the Task Force: Permanent Coordination

The Task Force is transitional. So that the work does not end with its mandate, it hands over to a permanent body. Several proposals for that body now exist, from this blueprint, BioCanRx, the Senate Banking Committee and others in the life sciences community, and they are merged here into one:

#A Permanent Coordinating Authority and a Lab-to-Ownership Registry

Problem
A discovery moving from lab to patient passes through the granting councils, ISED and its capital programs, Health Canada, PHAC, Canada's Drug Agency and provincial payers. Each works to its own mandate, no one is accountable for the handoffs, and no one tracks whether federally funded discoveries reach patients, or whether the companies built on them stay Canadian. Several proposals now point at the same gap: this blueprint's transitional Implementation Task Force and Exit Registry (3G.1); BioCanRx's permanent translational oversight function with a national clinical trials registry; a central authority with power to make departments work together on handoffs; and the Senate Banking Committee's call for a single SME Office under one minister, accountable for oversight across all federal business innovation and growth programs (Senate BANC, 2026, Recommendation 1).
Proposal
Merge them into one permanent authority, set up in law to succeed the Task Force, with three functions. Coordinate: a single accountable head reporting to a lead minister, authority to set joint service standards and timelines for handoffs between ISED, Health Canada and PHAC, integrated teams of seconded staff, and a say over the program budgets in this package. Navigate: a translational concierge giving innovators one front door to funding, regulatory advice, manufacturing and reimbursement. Track: a lab-to-ownership registry that follows each federally funded discovery through every milestone: funding and readiness level (3H.6), Clinical Trial Application, trials, regulatory approval, reimbursement (absorbing the Exit Registry, 3G.1) and, finally, ownership: whether the company that holds the asset is still Canadian, and if it was sold, where the IP, jobs and trials went, and whether it has come home. When a foreign owner divests a Canadian-origin asset, the registry triggers the repatriation notice (3G.1). BioCanRx's proposed registry would follow a discovery from the lab to a clinical trial authorization; this one follows it to the end of the journey. The authority reports annually to Parliament. It measures and coordinates but does not select grant recipients, which stays with funders such as the Sovereign Drug Development Fund (3A.10), so the body that evaluates is not the body being evaluated. It hosts the industry exchange (3E.10), works with provinces through the parallel-review protocol (3G.3), and leaves Health Canada's independence in approving products intact.
Precedent
The Defence Investment Agency, which began operations in fall 2025 as a special operating agency within Public Services and Procurement Canada to centralize defence procurement expertise, with integrated teams drawing staff from PSPC, National Defence, the Canadian Armed Forces, the Coast Guard and ISED (PSPC, 2025); the UK Office for Life Sciences, a joint unit spanning three departments (GOV.UK); the U.S. National Center for Advancing Translational Sciences (NCATS), a dedicated federal translational research institute. SAIL's guidance likewise calls for long-term tracking of who controls, and who can access, publicly funded IP (SAIL guidance, pp. 19–20).
Evidence
A benchmarking study by the Institute on Governance (IOG), commissioned by BioCanRx and comparing Canada with six other countries, found that the health and economic development portfolios are complementary but operate without synchronization: translational research falls between them, too risky for the Health portfolio and without the guaranteed economic return ISED looks for (BioCanRx Annual Report 2025–26). Between 2002 and 2015, less than 1% of cancer immunotherapy clinical trials in Canada originated from Canadian research; from 2016 to 2024 the share rose to 4%, and BioCanRx alone accounted for 42% of those made-in-Canada trials (BioCanRx Annual Report 2024–25). No public record follows a funded discovery to its final owner. The best longitudinal record of what happened to Canada's public life sciences companies, how many survived, were acquired, failed or were repurposed, comes from the annual commentaries of Tony Pullen, a former healthcare investment banker, published from 2013 to 2017 (Pullen, 2013, 2015, 2017). No official body keeps this data.
Impact
Gives the package one owner, turns handoffs into managed transitions, and, for the first time, lets Canada see the whole path, including the last step no one measures today: whether the company is still Canadian.
Points of Debate
A new body can add a layer instead of removing one, so it should absorb or wind down overlapping coordination bodies, and without budget authority it becomes another convener. Critics of the Defence Investment Agency argue that splitting authority among several ministers repeats the structure that undermined earlier reforms (Davies, CDA Institute, 2025), which is why this authority has a single head. BioCanRx proposes housing oversight in an organization with end-to-end translational expertise that also selects fund recipients, a role it is positioned to fill, while its own brief to the Science and Research Committee argues for independent, Auditor General-style evaluation; this design separates the two. Tracking ownership requires company reporting, which should be tied to existing funding conditions to limit the burden. Provincial jurisdiction over health care delivery limits what a federal authority can require.

Program Continuity. National infrastructure in this package, including research platforms, trial networks and training programs, is funded on terms of at least seven years, with renewal based on performance, rather than three-year envelopes that end in a cliff. The Clinical Trials Fund, which supported Canada's clinical trial training platforms, including the CANTRAIN consortium, was a Budget 2021 commitment of $250 million over three years, with CIHR funding available until the end of March 2025 [CIHR, 2022]; the remaining money was partly re-profiled into 2025–26 [CIHR, 2025]. When time-limited money ends, the networks, trained staff and momentum built with it are lost, and the next program starts again from zero.

Phase I: Structural Launch and Investor Alignment (First 6 Months)

Phase II: Budget Measures and Statutory Drafting (Months 6 to 18)

Phase III: Market Intervention and Procurement Tendering (Years 1 to 3)

Phase IV: Institutional Execution and Governance (Years 2 to 5)

Closing

Canada has the science, the talent and the capital appetite to build life sciences companies that scale and stay Canadian-owned. What it lacks is a coordinated policy architecture. The aim of this blueprint is not more discovery funding, but the same urgency applied to the commercialization, procurement and access stages where Canada consistently loses what it builds, and to each of the three valleys a company must cross: from the lab to a fundable company, through scale-up, and to the anchor stage of listing and staying Canadian-owned. By implementing these structural reforms, the federal government can turn systemic innovation leakage into lasting national wealth, so that Canadian discoveries strengthen both the health of Canadian patients and the prosperity of the Canadian economy. That urgency has to come from the top. Life sciences should be a national priority led by the Prime Minister and a standing item on the Cabinet agenda, with one minister accountable for results, and with the provinces and territories brought in as partners through dedicated funding rather than as the target of conditions.

Part 5: References

Capital, commercialization and tax

Access, reimbursement and clinical trials

Procurement, data and sovereignty

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