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Home / Resources / Law and Policy Submissions

Law and Policy Submissions

Recent documents are in both PDF and html formats but all may be available in alternate formats on request.

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IWC submissions to the Minister … re Bill 105 – Schedule 9

May 14, 2026 by IWC Community Legal Clinic

IWC supports sections of the Bill that expand coverage to uncovered workers, increase the Loss of Earnings (LOE) benefits rate, and allow for LOE benefits to continue after the age 65 cut-off. However the Clinic finds that these changes are incomplete and proposes recommendations on LOE and Loss of Retirement Income, benefit retroactivity, retirement age […]

Download IWC submissions to the Minister … re Bill 105 – Schedule 9 Continue readingIWC submissions to the Minister … re Bill 105 – Schedule 9

ONIWG Submission to the Standing Committee on Finance and Economic Affairs re Bill 105 – Schedule 9

May 14, 2026 by Ontario Network of Injured Workers Groups

ONIWG Submission on amendments to the Workplace Safety and Insurance Act makes recommendations on benefits issues including restoring and backdating the Loss of Retirement Income 10% rate; providing universal coverage; and deleting that section of the bill that would eliminate the 72-month lock-in. The submission also references announced closure of the IWOS program.

Download ONIWG Submission to the Standing Committee on Finance and Economic Affairs re Bill 105 – Schedule 9 Continue readingONIWG Submission to the Standing Committee on Finance and Economic Affairs re Bill 105 – Schedule 9

ONIWG-RAC Submission to the Standing Committee on Finance and Economic Affairs re: Bill 105 – Schedule 9

May 13, 2026 by Ontario Network of Injured Workers Groups - Research Action Committee

Submission addresses the Bill 105 amendments to the Workplace Safety and Insurance Act (including age 65 cutoff, extended coverage and elimination of 72-month lock-in). It also details in depth, with recommendations, the further changes needed to ensure a fair workers’ compensation system for injured workers that is based on Meredith’s foundational principles.

Download ONIWG-RAC Submission to the Standing Committee on Finance and Economic Affairs re: Bill 105 – Schedule 9 Continue readingONIWG-RAC Submission to the Standing Committee on Finance and Economic Affairs re: Bill 105 – Schedule 9

OLCWCN letter re need for committee hearings on proposed WSIA amendments in Bill 105

April 28, 2026 by Ontario Legal Clinics' Workers' Compensation Network

Letter addresses issues of concern regarding the proposed changes to the Workplace Safety and Insurance Act in schedule 9 of omnibus Bill 105, Protecting Ontario’s Workers and Economic Resilience Act. In particular, the proposed elimination of the 72-month limit on the WSIB reviews of loss of earnings benefits and the use of unrelated social benefit […]

Download OLCWCN letter re need for committee hearings on proposed WSIA amendments in Bill 105 Continue readingOLCWCN letter re need for committee hearings on proposed WSIA amendments in Bill 105

IWC submission to WSIB consultation on independent living policies phase 2

June 19, 2024 by IWC Community Legal Clinic

Given the far-reaching scope of the review of the Board’s Independent Living policies and their potential impact, IWC submits that they require further in-person/online consultations with stakeholders, especially injured and ill workers, who will be the ones directly impacted by these policy changes.  The submission details major concerns on the modified/draft policies with recommendations.

Download IWC submission to WSIB consultation on independent living policies phase 2 Continue readingIWC submission to WSIB consultation on independent living policies phase 2

IWC submission to the Standing Committee on Bill 149

February 9, 2024 by IWC Community Legal Clinic

Submission prepared for IWC’s presentation to the Standing Committee on Social Policy (Feb. 12) comments on proposed changes (benefit indexation, occupational disease reform) to the Workplace Safety and Insurance Act in Schedule 4 of Bill 149, the Working for Workers Four Act. Clinic highlights that the strong financial position of the WSIB creates an opportunity […]

Download IWC submission to the Standing Committee on Bill 149 Continue readingIWC submission to the Standing Committee on Bill 149

ODRA submission to the Standing Committee on Bill 149

February 2, 2024 by Occupational Disease Reform Alliance

Submission prepared for ODRA presentation Feb. 13 to the the Standing Committee on Social Policy draws attention to what is missing in Bill 149. While supporting addition of an esophageal cancer presumption for firefighters, the Alliance details why “such piecemeal provisions do not address major problems with the way the WSIB engages in occupational disease […]

Download ODRA submission to the Standing Committee on Bill 149 Continue readingODRA submission to the Standing Committee on Bill 149

ONIWG-RAC submission to the Standing Committee on Bill 149

February 2, 2024 by Ontario Network of Injured Workers Groups - Research Action Committee

While supporting the Bill’s introduction of an additional indexing factor for workers’ compensation benefits, the submission proposes additional measures to address injured worker poverty: adjusting the WSIB Loss of Retirement Income so it equals the losses in contributions to the Canada Pension Plan (CPP); restoring the WSIB benefit level to 90% of net income as […]

Download ONIWG-RAC submission to the Standing Committee on Bill 149 Continue readingONIWG-RAC submission to the Standing Committee on Bill 149

ONIWG-RAC submission to pre-budget hearings

January 31, 2024 by Ontario Network of Injured Workers Groups - Research Action Committee

Presentation to the Ontario Legislative Assembly Standing Committee on Finance Economic Affairs pre-budget hearings in Thunder Bay focuses on cost-shifting from the WSIB to provincial coffers and the financial impacts of the current workers’ compensation system.

Download ONIWG-RAC submission to pre-budget hearings Continue readingONIWG-RAC submission to pre-budget hearings

ONIWG letter re New Years’ resolutions

January 23, 2024 by Ontario Network of Injured Workers Groups

“New Years Resolutions” for the Workplace Safety and Insurance Board and Minister of Labour collected from injured workers and their allies make clear that changes are urgently needed to have Ontario’s workers compensation system serve their needs better and more justly.

Download ONIWG letter re New Years’ resolutions Continue readingONIWG letter re New Years’ resolutions

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