An Overview of the Regulated Professions Neutrality Act + What It Means for Regulators

On November 20, 2025, Bill 13: Regulated Professions Neutrality Act (“RPNA”) passed first reading in the Alberta legislature. The RPNA reflects the belief that individuals should not be discouraged from holding a wide array of views on political, historical, social or cultural issues and, moreover, from freely expressing their opinions and beliefs. It also reflects the belief that professional regulatory bodies protect the public interest by setting standards of competence and ethical conduct for regulated professionals, and should not act beyond this scope.

The RPNA will eventually apply to over 100 regulated professions, including lawyers, engineers, teachers, doctors, health professionals, architects, accountants, accredited tradespeople, and many more. If passed, the legislation will significantly limit the ability for professional regulators to exercise their authority over speech and will significantly reshape mandatory education and equity-related policies. For many regulators, Bill 13 will require careful consideration of their policies and may alter long-standing approaches to professional governance and regulation.

This article outlines the key provisions of the RPNA and the practical implications for regulators and regulated professionals.

Limits on Sanction for Expression Outside the Profession

The RPNA restricts regulators’ ability to impose sanctions for a professional’s “expressive conduct” occurring outside the practice of the profession (s. 5). “Expressive conduct” includes any activity or communication that conveys meaning, excluding violence or property damage.

Section 4 of the RPNA defines the “practice” of a profession broadly, to include:

• Provision of professional services, including ancillary or related activities.
• Activities related to business operations associated with professional services.
• Interactions with clients, colleagues, or others in professional settings.
• Interactions with regulatory bodies.

A regulator may not sanction expressive conduct outside the practice of the profession unless:

• A statute expressly authorizes discipline outside the practice of the profession, and
• The conduct falls into a narrow list of permitted grounds, including:
  • Threats of physical violence.
  • Misuse of professional position with the intention of causing harm to an identifiable person.
  • Expressive conduct that has resulted in a criminal conviction.
  • Boundary violations involving clients, patients, students, or their families.
  • Sexualized expressive conduct involving clients, patients, students, the families of these individuals, minors, or individuals encountered through professional practice.
  • Sexualized communications to minors or students.
  • Distribution of sexual images intended for minors/students or distributed on non-adult-restricted platforms.

The RPNA will update several existing laws to clarify that certain regulators may discipline behaviour that is expressive and occurs outside the practice of the profession if it falls under the exceptions in the RPNA. This will include the Professional Governance Act, the Health Professions Act, the Education Act, the Legal Profession Act, and others. However, not all regulatory legislation will be amended. Regulators for some professions will be unable to discipline registrants for any expressive conduct that occurs outside the practice of the profession without exception.

What This Means

Regulators will be unable to sanction professionals for online statements, political expression, controversial opinions, or other off-duty speech unless it falls into the specific categories above and a statute independently authorizes such sanctions.

This is a major shift. Until now, regulators have been able to impose discipline for “off-duty expression” where the expression negatively impacts the interests of the public or tends to harm the reputation of the profession. The RPNA sharply narrows this ability to address comments made by professionals.

Mandatory Neutrality on Certain Principles

Section 6 of the RPNA prohibits regulators from promoting or enforcing principles that assign value, moral superiority, bias or oppression, privilege, disadvantage, responsibility for actions, adverse or preferential treatment based on enumerated personal characteristics such as race, colour, ancestry, national or ethnic origin, sex, gender identity, religion, political or conscientious belief, and sexual orientation.

Regulators may not:

• Promote or affirm these principles.
• Act or make a decision, or omit to act or make a decision, in accordance with them.
• Maintain or create policies or other governing instruments reflecting them.

What This Means

This will affect regulator policies, competency matrices, codes of ethics, standards of practice, DEI frameworks, and training materials that:

• Address inherent bias, including unconscious bias, or privilege tied to personal characteristics.
• Promote preferential or adverse treatment to achieve diversity or inclusion.
• Rely on frameworks (including anti-racism or anti-bias models) that attribute systemic characteristics to individuals based on identity.

Limits on Mandatory Education and Training

Under section 7 of the RPNA, regulators may only impose mandatory education or training that relates to professional competence or ethical standards for the practice of the profession. Education or training on political, social, cultural, or historical matters is allowed only if:

• It directly and specifically relates to professional competence or minimum ethical standards.
• It is necessary to provide effective education or training.
• It does not dictate, expressly or by implication, the range of acceptable or unacceptable beliefs or opinions on any political, historical, social or cultural issue or on a matter of conscience.

Section 8 of the RPNA goes on to absolutely prohibit certain types of education or training, even if it is connected to competence or ethical standards, including education or training that addresses:

• Cultural competency.
• Unconscious bias.
• Diversity, equity, and inclusion.
• Any other subjects specified in the regulations.

The RPNA does not define any of these terms, but does clarify that a reference to diversity, equity or inclusion in the RPNA does not affect a person’s rights, responsibilities, or duties under the Alberta Human Rights Act (s. 1(2)).

What This Means

The restrictions on education and training will have a significant impact on what regulators can require from their registrants. While any education and training can still be offered on a voluntary basis, only education and training relating to professional competence or ethics can be mandatory.  In addition, even if it does relate to competence or ethics, the education or training must be necessary and must not dictate or imply that particular beliefs or opinions are acceptable or unacceptable.

Standard of Review Is Correctness

Section 10 of the RPNA establishes correctness as the standard of review for compliance with the RPNA, as well as any issue involving the Canadian Charter of Rights and Freedoms or Alberta Bill of Rights. This applies to both internal regulatory appeals and any judicial review.

What This Means

This is a departure from administrative law principles, where reasonableness is the presumptive standard of review. A correctness standard provides for a higher level of scrutiny, meaning that reviewing bodies owe less deference to the decision maker that came before them.

Coming into Force and Transition

If enacted, the RPNA will come into force upon proclamation. As of now, there has not been any indication as to when that may occur or how much time regulators will have to ensure they are compliant with the provisions.

Once the RPNA is proclaimed, ongoing disciplinary or other proceedings at the initial stage will be determined according to the RPNA. However, appeals within the regulatory body, judicial reviews and appeals to court that are already underway will be decided under the law as it existed before the RPNA was proclaimed.

What This Means

Regulators with active investigations or hearings when the RPNA is proclaimed will have to ensure immediate compliance. Regulators should also review their existing policies and mandatory education and training to ensure they are in a position to comply with the RPNA once it is in force.

What Regulators Should Do Now

If passed, the RPNA will require substantial policy and operational changes upon coming into force. Steps regulators should engage in now as part of planning for the RPNA include:

Review Codes of Ethics and Conduct

Regulators should identify provisions that regulate off-duty expression, refer to dignity, respect, DEI, discrimination, privilege, inherent bias, or similar concepts, or that could be viewed as inconsistent with neutrality requirements.

Audit Education and Training Requirements

Regulators should identify any mandatory training related to cultural competency, DEI, or unconscious bias and plan how to make such training voluntary. Regulators should also ensure all mandatory education and training will be tied directly to competence or minimum ethical standards.

Review Regulator Policies and Practices

Regulators should review all policies and practices that are connected to principles that involve DEI, specific treatment connected to personal characteristics, or that may involve certain values, privileges, or disadvantages connected to personal characteristics. This review should go beyond just the policies and practices that directly apply to the conduct of registrants as the neutrality requirement is expansive and applies to all actions and decisions of the regulator.

Update Investigations and Discipline Processes

Regulators should develop screening tools to determine whether alleged unprofessional conduct is “expressive conduct” outside the “practice of the profession” as defined in the RPNA. 

Conclusion

The RPNA represents a significant change to Alberta’s professional regulatory landscape. By introducing strict neutrality requirements, limiting mandatory education and training, and narrowing disciplinary jurisdiction over expression, the RPNA sets overarching principles for how professional regulatory bodies should regulate their registrants.

If you would like assistance understanding the impacts of Bill 13 for your organization, our Professional Regulatory Group is available to help.