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Ontario Moves to Regulate Preferred Pharmacy Networks (PPNs)

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Overview

Life Sciences Bulletin

The government of Ontario has signaled its intention to formally regulate preferred pharmacy networks (“PPNs”) in employer-sponsored drug benefit plans. According to the 2025 Fall Statement released on November 6, 2025, the government announced that it will introduce legislation implementing an “Any Willing Provider” framework along with a standardized, transparent process for patients to seek exemptions from PPNs where appropriate.

Although few details of the proposed legislation are provided in the 2025 Fall Statement, a cornerstone of this initiative will be the ability of any pharmacy to participate in the network and dispense to plan members if willing to match the PPN’s financial terms. While PPNs will not be prohibited, the Any Willing Provider framework will effectively eliminate exclusive dispensing arrangements in employer-sponsored drug benefit plans. According to the government, opening PPNs to broader participation will enable expanded consumer choice and competition in the pharmacy sector while maintaining cost effective access to medications.

The government’s announcement follows extensive consultations with stakeholders in Ontario’s pharmacy sector over the last several years, as well as consultations with other provinces and receipt of input from the federal Competition Bureau. The Ontario College of Pharmacists has advocated for the regulation of PPNs, on the basis that closed dispensing networks have the potential to fragment and diminish continuity of care, create access inequities, and reduce patient autonomy.

Stay tuned for further updates and analysis when the new legislation is tabled.

Contact the Authors

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Contact the Authors

Authors

  • Timothy M. Squire, Partner | CO-LEADER, LIFE SCIENCES, Toronto, ON, +1 416 868 3462, [email protected]
  • David C. Rosenbaum, Partner | Litigation and Dispute Resolution, Toronto, ON, +1 416 868 3516, [email protected]
  • Ingrid E. VanderElst, PhD, Partner | Trademark Agent | Intellectual Property, Toronto, ON, +1 416 865 4519, [email protected]
  • Jean-Raphaël Champagne, Partner | Life Sciences, Emerging Technology & Venture Capital, Québec, QC, +1 418 640 2084, [email protected]
Timothy Squire Toronto Lawyer Timothy M. Squire Partner | CO-LEADER, LIFE SCIENCES Toronto, ON +1 416 868 3462
David Rosenbaum Toronto Lawyer David C. Rosenbaum Partner | Litigation and Dispute Resolution Toronto, ON +1 416 868 3516
Ingrid Vanderelst Toronto Lawyer Ingrid E. VanderElst, PhD Partner | Trademark Agent | Intellectual Property Toronto, ON +1 416 865 4519
Jean-Raphaël Champagne Avocat/Associate Québec Jean-Raphaël Champagne Partner | Life Sciences, Emerging Technology & Venture Capital Québec, QC +1 418 640 2084