No Time to Stall: Alberta’s 120-Day Approvals Act Explained

On April 14, 2026, Minister for Energy and Minerals, Brian Jean, tabled Bill 30, the Expedited 120-Day Approvals Act (“Bill 30”), promising a new legislative framework to ensure an expedited approval and authorization schedule for major projects in Alberta. While Bill 30 has completed all three readings in the Alberta Legislature, it is not yet in force but should it be implemented, it promises a significant overhaul for Alberta energy producers and developers going forward. Minister Jean stated that Bill 30 will assist in Alberta’s goal of “doubling oil and gas production by 2035 and increasing market access”.

Background 

Within the past year, the goal of accelerating major project approvals has been a focus of both the federal and provincial governments. On November 27, 2025, the Alberta and Canada signed a memorandum of understanding (“MOU”) that, among other things, aimed to fast-track the approval and development of pipelines carrying Alberta oil, as well as carbon capture, utilization and storage projects, and inter-provincial electrical transmission interties (for more information about the MOU, see our pervious article here [https://www.mross.com/what-we-think/article/federal-provincial-cooperation-in-the-canada-alberta-electricity-mou]). 

The Terms of Bill 30

The terms of Bill 30 are ambitious. Under the proposed provisions, a project proponent may apply to the appropriate Ministry for their project to be designated a “qualified project”.[1] In evaluating the application to designate a project a “qualified project”, Bill 30 provides various considerations for the Ministry to contemplate, including whether:

• the project “strategically aligns with the Government’s priorities, goals and outcomes”;
• the project “is of strategic importance to Alberta’s economy” considering the potential increased investment, job creation, economic activity and Government revenue;
• the benefits of the project outweigh any “residual impacts”;
• the project meets the threshold for capital spending, which is $250 million dollars;
• the project “advances national and provincial security by recognizing provincial autonomy” and simultaneously respecting Alberta’s areas o jurisdiction. [2]

This list is not exhaustive, meaning that the applicable Ministry will have considerable discretion in deciding whether a project ought to receive the “qualified project” designation. However, the minimum capital spending threshold of $250 million does suggest that Bill 30 is aimed at accelerating major development projects in Alberta, rather than smaller scale, local projects.

Once the Ministry has evaluated the application, they can recommend cabinet either accept or reject the designation.[3] If accepted, cabinet must provide which approvals the projects requires and provide a deadline in which those approvals must be obtained in an order. It is these timelines for approvals that are the most consequential provision of Bill 30. Under the current proposed Bill 30, qualified projects must receive their decision for each required approval within 120 days of an order being provided, or the established timeframe to receive an approval under a different statute, whichever expires first.[4] This new timeline is mandatory, though the Ministry does have the ability to rescind the “qualified project” designation where “extraordinary circumstances that materially affect a qualified project” arise.[5]

Another important feature of Bill 30 is it’s paramountcy provision: where provisions of any other statute conflicts with Bill 30, the provisions of Bill 30 will prevail.[6] This emphasizes the importance that the Government of Alberta is placing on speedy developments of projects in Alberta and emphasizes that objectives found in other legislation, such as environmental regulation and Indigenous consultation, may be secondary to expedient project development.

Implications

Bill 30 largely relies on discretion from Ministries to recommend the “qualified project” designation for various projects, while considering factors like areas of Alberta’s jurisdiction, benefits to Alberta’s economy and increases in government revenue.

Within the first reading, Minister Jean stated that Bill 30 will assist in Alberta’s goal of “doubling oil and gas production by 2035 and increasing market access”. While there is nothing in Bill 30 that restricts “qualified projects” to those in the oil and gas sector, there are indications that rapidly developing the energy sector is a key focus of implementing Bill 30, which is of course closely intertwined with the Alberta economy and government revenue.

The 120-day timeline to garner approvals for a “qualified project” is an ambitious target and, if enacted, would have numerous impacts on the current regulatory approval process in Alberta. For starters, there is no mechanism to address how impacted parties may voice their support or concerns with respect to a proposed project, and it is unlikely that regulatory bodies would be able to hold a public hearing within this truncated timeline for approval. The same implications hold for meaningful Indigenous consultation or environmental assessments, the former being a constitutional requirement of all governments in Canada.

There are also concerns that this quicker timeframe may result in rushed project planning or incomplete environmental assessments, which may translate into unexpected delays in the construction of qualified projects. This is particularly so given that the quicker timeframe is meant to apply to major projects, which naturally have broader impacts and require more planning prior to a project being developed. On the other hand, it may prompt more efficient and focused planning for proponents to ensure the 120 day timeline is met.

The legislative frameworks laid out in Bill 30, if successfully passed and implemented, could lead to quicker approvals of major development projects approved by the Government and may thus inject more economic activity on a quicker pace. However, the benefits of an expedited timeline must be balanced with ensuring obligations of Indigenous consultation and environmental assessment are still being met. While Bill 30 is not yet in force, it does promise major reforms in the way proponents and regulators will get shovels in the ground for major projects in Alberta.