The Information and Privacy Commissioner of Ontario (IPCO) released its 2025 Annual Report earlier this month. Entitled Strong Foundations for a Changing World, the report reviews IPCO’s activities over the past year and outlines its 2026–2030 Strategic Plan.
A separate 2025 Statistical Report provides detailed statistics on freedom of information requests, appeals, privacy complaints and other matters across Ontario.
For FOI professionals, one of the most notable findings is the continued—and accelerating—growth in the use of Ontario’s freedom of information system.
FOI Requests Increase by More Than 20%
Ontario institutions received 84,402 freedom of information requests in 2025, an increase of more than 20% from the 70,293 requests received in 2024.
Of the 84,402 requests received:
- 51,182 were submitted to municipal institutions under MFIPPA (vs. 41,947 in 2024); and
- 33,220 were submitted to provincial institutions under FIPPA (vs. 28,346 in 2024).
Requests were divided almost evenly between personal information and general records, with 43,531 requests for personal information and 40,871 requests for general records.
Ontario institutions completed 77,869 FOI requests during 2025. Municipal institutions completed 48,515 requests, while provincial institutions completed 29,354.
Individuals continued to account for the majority of completed requests. Of the requests for which the source was reported, 39,217 came directly from individuals and another 17,207 were submitted by individuals through an agent. Businesses accounted for 13,860 completed requests, while the media accounted for 1,406.
Most Requests Resulted in at Least Some Disclosure
Of the reported outcomes for requests completed in 2025:
- 20,202 resulted in all information being disclosed;
- 32,033 resulted in information being disclosed in part;
- 9,155 resulted in no information being disclosed; and
- 10,514 found that no responsive records existed.
Institutions collected approximately $1.15 million in FOI fees during the year, including application fees and additional processing fees, while approximately $89,600 in fees were waived.
Response Times
Across Ontario’s municipal institutions, 81.8% of requests were completed within 30 days, while IPCO reports an 86.5% “extended compliance” rate, takes into account requests involving time extensions or affected-person notices. Approximately 3.7% of municipal requests took more than 90 days to complete.
Provincial institutions faired slightly worse, completing 72.1% of requests within 30 days, with an extended compliance rate of 80.6%. Approximately 9.8% of provincial requests took more than 90 days.
The Statistical Report also provides institution-by-institution response rates for ministries, agencies, hospitals, colleges and universities, school boards, police services and municipal corporations, allowing institutions to compare their request volumes and performance against similar organizations. The full raw data is available here.
Appeals Also Rose Sharply
The increase in FOI requests was accompanied by an even larger increase in access to information appeals.
IPCO opened 2,296 FIPPA and MFIPPA access appeals in 2025, compared with 1,731 in 2024—an increase of approximately 33% in a single year. Of those appeals, 1,267 involved municipal institutions and 1,029 involved provincial institutions.
The most frequently identified issue was the application of an exemption, which accounted for 957 appeals. Other significant issues included:
- 411 deemed-refusal appeals;
- 225 reasonable-search appeals;
- 178 appeals concerning whether the legislation applied; and
- 157 third-party appeals.
IPCO closed 1,956 access appeals during 2025, including 1,062 municipal appeals and 894 provincial appeals. Since the number of new appeals exceeded the number closed, however, IPCO’s inventory of outstanding access appeals continued to grow.
Since 2023, IPCO has faced a growing imbalance between new and closed access appeals, with 2025 marking the largest gap: 2,296 new appeals were opened, while only 1,956 were closed.
| Year | Opened | Closed | Net increase in open appeals | Cumulative increase since start of 2023 |
|---|---|---|---|---|
| 2023 | 1,566 | 1,441 | 125 | 125 |
| 2024 | 1,731 | 1,431 | 300 | 425 |
| 2025 | 2,296 | 1,956 | 340 | 765 |
| Total | 5,593 | 4,828 | 765 | — |
Despite the growing caseload, the average time required to close an access appeal declined slightly, from 9.9 months in 2024 to 9.7 months in 2025. This continues a trend of improvement downwards from the 12 to 12.5 month averages reported in 2021 and 2022.
IPCO has also continued to emphasize resolving cases without a full adjudication. In 2025, 796 appeals were closed through IPCO’s new expedited process (launched in 2024) and 684 at mediation, while 384 were closed at adjudication.
A New Strategic Plan for 2026–2030
The Annual Report also outlines IPCO’s 2026–2030 Strategic Plan, presenting its vision of being “a modern and effective regulator with real-world impact.” Its updated mission focuses on enhancing Ontarians’ trust that their privacy and access rights will be respected in what IPCO describes as a period of “digital intensification.”
The plan is organized around three broad pillars: Advocacy, Responsiveness and Accountability.
From an FOI perspective, the Responsiveness pillar is particularly noteworthy. Among its stated goals for the next several years, IPCO asserts that it intends to:
- Define and uphold service standards and operational timelines.
- Issue clear, concise, and plain language decisions that support compliance.
- Enhance understanding of the law and tribunal processes through education and actionable guidance based on systemic trends and lessons learned from past cases.
Privacy, AI and Cybersecurity
Beyond access to information, much of the Annual Report focuses on the challenges created by rapidly evolving technology.
Among other initiatives, IPCO highlights its work on responsible artificial intelligence, including joint principles for the responsible use of artificial intelligence developed with the Ontario Human Rights Commission; updated guidance on de-identification; cybersecurity and ransomware decisions and investigations; children’s digital privacy; genetic genealogy used by police; and recommendations in support of privacy protections within Ontario’s increasingly digital health system.
Bill 194
The report also mentions IPCO’s efforts in 2025 to help provincial institutions prepare for the new obligations introduced through the Bill 194 amendments to FIPPA, which also expanded IPCO’s oversight powers.
What the Numbers Tell Us
For Ontario FOI practitioners, perhaps the clearest message in the 2025 reports is simply that demand on the access-to-information system continues to grow.
More than 84,000 FOI requests were filed in Ontario in 2025, representing a year-over-year increase of more than 20%, while the number of access appeals increased by approximately one-third. At the same time, institutions and IPCO are being asked to adapt to new technologies, new privacy obligations and increasingly complex records environments.
IPCO’s emphasis in its strategic plan on timeliness, practical guidance and efficient digital services therefore arrives at an important time for both the regulator and for the institutions it oversees.
The 2025 Annual Report and 2025 Statistical Report are both available from the Information and Privacy Commissioner of Ontario.
Managing Growing FOI Volumes
As FOI request volumes continue to rise, institutions increasingly benefit from tools that help them prepare FOI correspondence and manage deadlines, fees, the affected-person process, staged access plans and other procedural requirements in a consistent and organized way.
The FOI Assist Software is Ontario-focused freedom of information case-management software designed to help institutions manage FOI requests from intake through completion. The software tracks statutory deadlines, generates correspondence and notices, assists with fee calculations and time extensions, and provides a centralized record of each request and the steps taken to process it.
FOI Assist also includes online request submission and tools for managing routine disclosure requests, helping institutions reduce administrative work while maintaining a clear and consistent FOI process.
To learn more about the FOI Assist Software or to arrange a demonstration, contact FOI Assist today.
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