Ontario's Growing Accountability Gap

In the same statement, Commissioner Kosseim pointed out that FIPPA already protects personal, confidential, and constituency records from being released. She said the proposed change goes further, it would also exclude government-related business records held by elected officials and their staff.

The IPC's statement raised three additional concerns. First, the changes would apply retroactively to 1988, the year FIPPA took effect. Nearly four decades of government records would be placed outside FIPPA's reach. Second, the bill would weaken the IPC's oversight of FIPPA's data-linking rules, which allow the government to connect personal records across departments, including health information. The IPC called this “an inherent conflict of interest that seriously weakens accountability.” Third, the bill would let government employees carry email accounts containing personal information when they change ministries. The IPC said this “increases the risk of privacy breaches exponentially.”

Commissioner Kosseim also published an opinion piece in The Globe and Mail on March 16, 2026, titled “Ontario steps back into the information dark ages,” further elaborating on the constitutional and democratic implications of the proposed changes.

This analysis focuses on structural accountability gaps in Ontario's freedom of information framework as they relate to publicly funded autism services. It does not allege that AccessOAP, Accerta Services Inc., Serefin, Autism Ontario, McMaster University, or any other individual, political party, or organization has acted improperly, misused public funds, or failed to deliver on contractual obligations.

The Ontario government's stated reasons for the proposed FIPPA amendments are presented in full above. This analysis includes all three opposition parties' published positions. Readers are encouraged to consult the original government news release, the IPC Commissioner's full statement, and the referenced news reports directly.

Accountability is not adversarial. Effective transparency mechanisms serve well-run programs as much as they expose poorly-run ones, by providing independent validation that public money is being well spent and public trust is being earned.