Thank you for the opportunity to comment on the proposed regulations supporting the Municipal Accountability Act, 2026. Civic Ontario support the Province’s objective of establishing a clear, consistent, and credible accountability framework for members of municipal councils and local boards across Ontario.
A province-wide code of conduct, supported by consistent inquiry processes, appropriate training, and an effective discipline framework, can strengthen public confidence in local government. To achieve that objective, the regulatory framework must also be practical to administer, procedurally fair, sufficiently independent of local political dynamics, and responsive to the realities of municipal governance and administration.
We respectfully submit the following recommendations.

1. Council accountability and conduct
The prescribed code should include a statement of purpose similar to paragraph 4 of s. 1.1 of the Municipal Conflict of Interest Act: There is a benefit to municipalities and local boards when members have a broad range of knowledge and continue to be active in their own communities, whether in business, in the practice of a profession, in community associations, and otherwise.  The prescribed code should also  recognize that the primary role of a member of Council is to participate in the governing body’s responsibilities under the Municipal Act, 2001. This includes setting strategic direction, establishing policies, making financial decisions, representing the public interest, and holding the municipal administration accountable through Council’s collective authority.
The code should clearly distinguish the governance role of Council members from the administrative responsibilities assigned to the CAO and municipal staff. A member’s conduct should support, rather than undermine, the established Council–staff relationship, organizational structure, delegated authorities, and professional administration of municipal operations. A code that articulates this distinction will help reduce inappropriate interference in administration, support respectful and effective Council–staff relations, and provide clearer standards against which conduct can be assessed.
The Code should also apply to Advisory Committees of Council which have a majority of non-Council members. This would establish consistent standards of conduct for everyone advising Council and help maintain public confidence in the committee process.
We also strongly support the proposed emphasis on respect for staff. In practice, staff may have limited means to respond when inappropriate comments or conduct occur in a Council meeting or other public setting. The final code and related inquiry processes should provide meaningful protection for staff, make clear that disrespectful, harassing, discriminatory, retaliatory, or intimidating conduct is unacceptable, and ensure that concerns can be raised and addressed without fear of reprisal. The code should not emulate or spill over into territory covered in Occupational Health and Safety Act.

2. Conflicts of interest
The regulations should adopt a broader and more precise definition of family relationships that may give rise to a real, potential, or perceived conflict of interest. The need for this clarity is reinforced by lessons arising from municipal judicial-inquiry processes, including matters involving benefits received by relatives other than an immediate spouse or child.
For the purposes of the code and conflict-of-interest provisions, “family” should include:

• A spouse, common-law partner, or person with whom the member is living in a spousal relationship outside marriage.
• A parent, including a step-parent or legal guardian.
• A child, including a step-child or grandchild.
• A sibling and the children of a sibling.
• An aunt, uncle, niece, nephew, or first cousin.
• In-laws, including a mother-in-law, father-in-law, sister-in-law, brother-in-law, daughter-in-law, or son-in-law.
• Grandparents, including grandparents by marriage or common-law relationship.
• Any person who permanently resides with the member.

The regulations should also expressly apply conflict-of-interest requirements to Council advisory committees as well as municipal Agencies, Boards, and Commissions. While advisory committees may not make final decisions, their recommendations can materially influence Council deliberations, policy development, procurement, and financial decisions. Consistent standards across Council, local boards, and advisory bodies will better protect the integrity of municipal decision-making.
The code of conduct should include a prohibition against a member acting in a non-pecuniary conflict of interest. Numerous municipal codes of conduct include non-financial conflict of interest provisions that could provide guidance.  
 
3. Gifts and hospitality
We support clear, province-wide rules governing gifts and hospitality. However, the proposed cumulative annual threshold of $200 from a single source may be unnecessarily restrictive in ordinary municipal and community settings. The Province should consider a more practical threshold that continues to prevent improper influence while recognizing routine ceremonial, community, intergovernmental, and stakeholder interactions.
The final regulation should also address matters not clearly addressed in the current proposal:

• A clear prohibition on accepting gifts, hospitality, benefits, or other advantages from actual or prospective municipal procurement bidders, proponents, vendors, or their representatives, except where expressly permitted under narrow and transparent exceptions.
• A mechanism by which a member may seek advance guidance or approval from the Integrity Commissioner in uncertain circumstances.
• Authority for an Integrity Commissioner to order the return, reimbursement, surrender, or appropriate disposition of an improper gift or benefit.
• Clear disclosure requirements, including the nature, estimated value, source, date, and disposition of gifts or hospitality that are permitted or required to be disclosed.

These provisions would give members practical guidance while ensuring that the rules are enforceable and trusted by the public.

4. Complaints and inquiry process
The regulations should clearly specify who may submit a complaint. At a minimum, the process should be accessible to members of Council, municipal employees, local-board members, and members of the public who have direct knowledge of the alleged conduct. Staff who experience or witness misconduct must have a safe, confidential, and clearly defined avenue to bring forward concerns.
A provincial-wide uniform complaint form should be structured as a declaration or affidavit to provide a formal, legally binding statement of truth to support the specific facts alleged by a complainant.
The process should incorporate firm but reasonable timelines at each stage, including complaint screening, notice, response, investigation, pre-hearing or procedural conferences where applicable, reporting, and Council consideration. The process should be informed by the disciplined timelines and procedural structure used in other Ontario accountability regimes, including the pre-hearing framework under Ontario Regulation 404/23 made under the Community Safety and Policing Act, 2019.
Timeliness is essential. Delayed processes can prolong harm, increase costs, impair procedural fairness, erode public confidence, and create uncertainty for both complainants and respondents. The regulations should establish a default expectation that inquiries will be completed within prescribed timeframes, with written reasons required where extensions are necessary. The ultimate limitation period of 4 years from when something first occurred is much too long.
The regulations should also expressly encourage the appropriate use of mediation or other early-resolution processes. Not every complaint requires a full investigation. In suitable cases, voluntary, confidential, and professionally facilitated mediation may resolve concerns more quickly, reduce costs, restore working relationships, and allow Council and staff to refocus on municipal responsibilities. Mediation must not be used where it would be inappropriate, including in serious harassment, discrimination, violence, retaliation, or other cases involving significant power imbalances or public-interest concerns.
A member who is the subject of an inquiry must be given a final opportunity to comment on any proposed findings but there should be a specific timeframe set out for the member’s response to be provided
 
5. Integrity Commissioner capacity
The effectiveness of the new framework will depend substantially on the knowledge, independence, and capability of municipal Integrity Commissioners. The regulations should therefore establish minimum qualifications, competency standards, and continuing-education requirements for Integrity Commissioners.
At a minimum, an Integrity Commissioner should demonstrate expertise or equivalent professional competence in:

• Municipal law, administrative law, or legal principles relevant to municipal accountability.
• Procedural fairness, investigations, evidence assessment, and report writing.
• Municipal governance, Council–staff relations, and the statutory roles of elected officials and municipal administrators.
• Human rights, workplace harassment, discrimination, and workplace violence.
• Conflict-of-interest rules, ethics, procurement integrity, and public-sector accountability.
• Mediation, dispute resolution, trauma-informed practice, and culturally competent approaches, where relevant.

The Integrity Commissioner of Ontario should provide or coordinate standardized education and training for municipal Integrity Commissioners, and municipalities should receive clear information regarding the completion and status of that training. The Municipal Accountability Act already establishes a provincial role in advising on commissioner independence and delivering prescribed education and training; the regulations should use that authority to create a consistent, credible province-wide standard.
We also recommend that Integrity Commissioners be empowered to issue binding decisions within the authority provided by legislation and to impose appropriate remedies and sanctions directly, rather than relying unnecessarily on Council to determine outcomes. A more independent enforcement process would reduce the risk that discipline becomes politicized or that complainants and affected staff are required to repeatedly relive harmful experiences before a political body.

6. Training requirements
The proposed training requirements should be strengthened. Training should not be limited to the mechanics of the code, complaint process, or procedural requirements. All members of Council, members of applicable local boards, and relevant staff should be required to complete annual training on:

• The prescribed code of conduct and conflict-of-interest obligations.
• Respectful workplace expectations and Council–staff relations.
• Workplace harassment, discrimination, violence, bullying, retaliation, and bystander responsibilities.
• Human rights and equity obligations.
• Governance versus administration, including the role of Council, the Mayor, the CAO, and municipal staff.
• Gifts, hospitality, procurement integrity, and use of confidential information.
• The complaint process, procedural fairness, and available early-resolution options.

The code should expressly require members to comply with municipal or local-board policies respecting workplace violence and harassment established under section 32.0.1 of the Occupational Health and Safety Act. Annual training will help move the framework from a reactive discipline model to a preventative culture of respectful, ethical, and effective municipal governance.

7. Discipline and removal from office
The regulations should establish a graduated, standardized range of remedies and sanctions, similar to the structured approach used in other public-sector accountability frameworks. This would promote consistency, proportionality, transparency, and fairness across Ontario municipalities.
The available sanctions should include, in escalating order:

• A public or private reprimand, censure, or requirement for an apology.
• Mandatory education, coaching, counselling, or other remedial measures.
• Restrictions on a member’s attendance at meetings, where legally available and proportionate.
• Removal from, or restriction on appointment to, committees and local boards.
• Restrictions on serving as a committee or local-board chair or vice-chair.
• Suspension or other measures available under the governing legislation.
• Removal from office in the most serious and egregious cases.

For the most serious cases, it may be necessary to start with the highest sanction. The process for serious cases should also be independent of a Council vote wherever possible. We recommend that a municipal Integrity Commissioner and/or the municipality be authorized to apply to a judge for an order removing a sitting member of Council in defined, exceptional circumstances. This would reduce the risk that the matter becomes politicized and avoid placing complainants or victims in the position of having to await a decision by the same political body in which the respondent serves.
The legislation’s current removal mechanism involves both a municipal Integrity Commissioner and the Integrity Commissioner of Ontario, followed by a Council vote within 30 days. The vote must be unanimous among eligible members. If the Province retains this Council-vote model, the unanimous threshold should be amended to a supermajority threshold, such as a two-thirds vote of eligible members. A unanimous-vote requirement creates a substantial risk that an otherwise well-supported finding of egregious misconduct cannot result in an appropriate consequence.
Members removed from office for serious misconduct should be barred from seeking re-election for the remainder of the current term and the subsequent term. The Act currently provides for a four-year disqualification following a successful vacancy declaration. The regulations and related framework should ensure that this consequence is clear, enforceable, and sufficient to uphold public confidence.

8. Political neutrality
The proposed code’s commitment to political neutrality is welcome. However, the regulations should be reviewed carefully to ensure that political-neutrality expectations can operate effectively in municipalities subject to strong-mayor powers and within the intended relationship between a Mayor and the CAO.
The Province should clarify that political neutrality does not diminish Council’s statutory governance role, the CAO’s responsibility for professional and impartial administration, or the obligation of municipal staff to provide objective advice to Council and its members. Clear guidance is particularly important where statutory powers, directions, and administrative accountability structures may create uncertainty about the respective roles of the Mayor, Council, and CAO.

9. Provincial guidance and consistency
The Province should establish an ongoing mechanism for interpreting and applying the framework as real municipal cases arise. We recommend that the Integrity Commissioner of Ontario issue formal circulars, guidance bulletins, interpretive notices, or a comparable public resource. These materials should identify recurring issues, explain how provisions are intended to apply, and provide anonymized examples grounded in Ontario municipal circumstances. Such a resource would assist municipalities, local Integrity Commissioners, Council members, local boards, and municipal administrators in applying the code consistently over time. It would also reduce unnecessary disputes, improve compliance, and allow local practices to evolve with a common provincial understanding.

Conclusion
We support the Province’s efforts to create a more consistent and effective municipal accountability regime. The proposed regulations will be strongest if they combine a clear and practical code of conduct with independent, timely, fair, and enforceable processes; meaningful protection for staff and complainants; robust training; competent and independent Integrity Commissioners; and sanctions that are proportionate to the seriousness of misconduct.
We encourage the Province to provide implementation guidance, model resources, and training materials sufficiently in advance to support an orderly transition by municipalities, local boards, elected officials, and Integrity Commissioners.
 
About Civic Ontario
Civic Ontario is the professional body for municipal CAOs and executive leaders operating at the centre of Ontario’s civic systems. It provides a trusted environment where senior leaders connect with peers, exchange perspectives, and strengthen their ability to navigate complexity and serve the communities that depend on them. Our origins go back to 1958 when a group of Chief Administrative Officers formed the Ontario Municipal Administrators Association to assist in the promotion of better local government. The Association was rebranded as Civic Ontario in 2026 to build upon the rich legacy of OMAA and extend itself to those operating at the centre of civic systems. 
https://civicontario.ca/