Treadstone Associates
Data · Cross-border review

Investment Canada Act filings and reviews

Every foreign acquisition of a Canadian business above a threshold gets certified, and every one deemed a national security risk gets a formal review — ISED reports both counts annually.

Treadstone Associates · Source: ISED, Investment Canada Act Annual Report 2024–25 · Fiscal year to 31 March 2025

Headline figure

1,138

Total Investment Canada Act filings in fiscal 2024–25: 1,128 notifications were certified and ten applications for net benefit review were approved as likely to be of net benefit to Canada — together representing over $132.5 billion of investment.

What the data says

  • • Net benefit reviews, the higher-scrutiny track reserved for the largest deals, averaged 102 days to complete — a real, sourced timeline component for any deal that trips the review threshold.
  • • National security reviews ran separately: 30 investments were subjected to extended review, with outcomes of 1 wind-up order, 6 permitted to proceed on enforceable undertakings, 9 withdrawn by the investor, and 14 concluded with no further action warranted.
  • 240 of the 1,128 certified notifications involved a genuinely new business being established in Canada by a non-Canadian, rather than the acquisition of an existing one.
  • • The reviewability thresholds themselves are statutory, not administrative: a direct acquisition of control is reviewable at $5 million or more in asset value (s. 14(3)), an indirect acquisition at $50 million. The much higher WTO-investor enterprise-value threshold is indexed annually and its current-year figure is published in the Canada Gazette, not on this report.

Notification versus review: two very different processes

Most inbound foreign investment in a Canadian business only needs a notification — a filing that gets certified, not reviewed. Formal net benefit review is reserved for transactions above the enterprise-value threshold, and it is a genuinely small population: 10 applications against 1,128 notifications in fiscal 2024–25. A national security review is a separate, discretionary track that can be triggered regardless of deal size.

What the outcome split tells a foreign sponsor

Of the 30 extended national security reviews, exactly one resulted in a wind-up order and 14 closed with no further action — the modal outcome for a deal that reaches extended review is that it clears, sometimes with undertakings attached. That is useful context against headline coverage of Canada's foreign investment regime, which tends to foreground the rare block rather than the typical clearance.

Two carve-outs the headline count hides

Not every foreign acquirer is measured the same way. Under ICA s. 14.1(1.1), a WTO investor that is a state-owned enterprise is measured on asset value, not the higher enterprise-value threshold that applies to other WTO investors — a materially lower bar for state-linked capital. And s. 14.1(5)–(6) exempts an investment to acquire control of a “cultural business” — defined to include book, magazine and newspaper publishing and distribution, film and video, music, and broadcasting — from the WTO-investor threshold entirely, routing it instead through the lower ordinary thresholds. The enterprise-value threshold itself is not a fixed number: s. 14.1(2) sets it every January using the formula “(Current Nominal GDP at Market Prices / Previous Year Nominal) × amount determined for previous year,” published in the Canada Gazette under s. 14.1(3) — the same indexing mechanism used elsewhere in Canadian merger law, and one more reason the dollar figure on this page should never be treated as this year’s number.

How to use it

Pair this with merger notifications and Competition Bureau outcomes for the domestic competition-law clock that can run in parallel on a large cross-border deal, and with how long a Canadian business takes to sell to see how these review periods stack onto an overall closing timeline.

Turn the numbers into a plan.

A 30-minute call is enough to tell you where AI pays for itself in sourcing, diligence and portfolio operations.

The Canadian benchmark

What do businesses like this one actually sell for?

Nobody publishes Canadian transaction data, so every valuation in this country quotes an American benchmark. We are building the Canadian one — multiples, asking-to-sale spreads and days on market, by sector and by city. Leave an email and you will see it first.

No pitch, no listings. One email when the first report lands.