On November 20, 2025, Alberta’s Minister of Justice tabled Bill 13, the Regulated Professions Neutrality Act (“RPNA” or the “Act”), which seeks to protect the free expression rights of regulated professionals.
Bill 13, informally referred to as the “Peterson Law,” follows Ontario’s Divisional Court decision in Peterson v. College of Psychologists of Ontario.[1] Justice Schabas, in writing for the Court, began his decision as follows:
When individuals join a regulated profession, they do not lose their Charter right to freedom of expression. At the same time, however, they take on obligations and must abide by the rules of their regulatory body that may limit their freedom of expression. This case raises the clash a regulated clinical psychologist’s right to speak in a certain manner and the regulator’s power to require the member to moderate the speech.[2]
The Divisional Court dismissed Dr. Peterson’s application for judicial review, upholding the investigatory committee of the College of Psychologists of Ontario’s (“College”) decision that required him to undertake coaching in respect of his professionalism in public statements in order to avoid making “statements about people that may be harmful to them and to the profession.”[3] This order concluded the College’s investigation into various public statements made by Dr. Peterson on social media and podcasts, which the College deemed may be “degrading, demeaning and unprofessional,”[4] and that posed a “moderate risk of harm to the public.”[5]
For more background on the Peterson decision see our previous commentary: Freedom of expression and the Jordan Peterson case: Divisional court upholds coaching requirement ordered by College of Psychologists.
Should Bill 13 be enacted, it could reshape how professional regulatory bodies respond to off-duty expression and introduce neutrality obligations. Note that the proposed legislation is intended to apply broadly across an extensive list of regulated professions in Alberta spanning skilled trades and occupations including law, education, engineering, accounting, and many others. [6]
What does Bill 13 propose about “off duty” expression?
Among other things, the RPNA seeks to prohibit professional regulatory bodies from sanctioning regulated professionals, including non-practicing regulated professionals or previously regulated professionals, for “expressive conduct”[7] undertaken outside of their professional capacity.
However, this protection is not without limits. Regulators would retain authority to respond to off-duty expression in narrowly defined situations, including where:[8]
- the expressive conduct was violent, or was intended to cause physical, psychological, or financial harm;
- the expressive conduct relates to an offence for which the regulated professional was convicted; or
- the expressive conduct relates to misconduct regarding professional boundaries with clients, patients, or students or their relatives, guardians, or caregivers, or inappropriately sexual in nature.
Barring these exceptions, healthcare regulators would be prohibited from sanctioning members for expression or conduct occurring off duty, outside the workplace, and beyond their professional role.
How does the proposed Bill 13 change neutrality obligations for healthcare regulators?
If enacted, the RPNA would require regulatory bodies to remain neutral regarding enumerated personal characteristics, namely, race, colour, ancestry, national or ethnic origin, religious belief, political belief, conscientious belief, sex, sexual orientation, or gender identity.[9]
This neutrality requirement would expressly bar regulators from promoting, affirming, acting on, or making or maintaining bylaws, policies, regulations, or other instruments based on certain principles. In practice, this would prohibit regulatory bodies from taking actions that demonstrate providing preferential or adverse treatment on the basis of these enumerated characteristics or the related principles as set out under the RPNA.[10]
Can regulators still require cultural competency or DEI training?
The RPNA further imposes strict limits on the authority of professions to mandate cultural competency education. Compulsory training would be permitted only where it is directly tied to the core competencies or ethical standards of the profession.
Notably, the RPNA would prohibit regulators from requiring cultural competency, unconscious bias, or diversity/equity/inclusion (DEI) training under any circumstances.[11]
How will courts review regulatory decisions under the RPNA?
To reinforce these new requirements, the RPNA proposes to set out a uniform legal standard for reviewing regulatory decisions, whether by a regulatory appeal body or the court. Where a decision is challenged on the basis that it breaches the Act or violates a professional’s fundamental rights, courts or appellate bodies must apply a strict “correctness” standard. This elevated standard creates a pathway for increased judicial scrutiny of regulatory decisions.[12]
Miller Thomson is actively monitoring the progress of this legislation and will provide further updates as developments occur.
For strategic guidance on how Alberta’s proposed RPNA may affect healthcare regulatory compliance, professional discipline, and institutional governance, contact our Health team or our Regulated Professionals team.
The RPNA is proposed legislation intended to limit when regulators can discipline professionals for off-duty expression and to enforce regulatory neutrality across regulated professions.
It may restrict the circumstances in which healthcare professionals can be disciplined for off-duty speech and limit mandatory training requirements imposed by regulators.
Yes. The legislation would prohibit mandatory cultural competency and DEI training, even if currently required by healthcare regulators.
Because the RPNA could alter disciplinary practices, increase judicial challenges, and impact governance and compliance obligations.
Ongoing regulatory proceedings would shift to the new RPNA framework once it comes into force, though existing appeals would remain under prior law.
[1] 2023 ONSC 4685.
[2] Peterson v College of Psychologists of Ontario, 2023 ONSC 4685 (“Peterson”) at para 1.
[3] Peterson at para 63.
[4] Peterson at para 43.
[5] Peterson at para 76.
[6] Bill 13, Regulated Professions Neutrality Act, Schedule 1.
[7] Bill 13, Regulated Professions Neutrality Act, s 5.
[8] Bill 13, Regulated Professions Neutrality Act, s 5.
[9] Bill 13, Regulated Professions Neutrality Act, s 6.
[10] Bill 13, Regulated Professions Neutrality Act, s 6.
[11] Bill 13, Regulated Professions Neutrality Act, s 8.
[12] Bill 13, Regulated Professions Neutrality Act, s 10.
