Canada’s health data revolution: New federal legislation may transform risk assessment and underwriting practices

Underwriting & Medical

Canada’s health data revolution:
New federal legislation may transform risk assessment and underwriting practices

3.5 minutes read

Published 06/25/2026

A doctor in a white coat discusses a tablet with a woman in a striped shirt in a medical office.

In February 2026, the federal government introduced Bill S‑5, the Connected Care for Canadians Act – legislation designed to address persistent inefficiencies in the Canadian health system caused by fragmented and inaccessible health data. While the bill primarily targets health-care delivery and patient safety, its downstream implications for risk assessment, evidence collection, and underwriting workflows are significant and warrant close attention.

The problem Bill S‑5 is attempting to fix

The federal government has acknowledged the current state of health data sharing in Canada, noting that only 29% of health-care providers can securely share electronic health information outside their practices.¹ At the heart of this issue are systemic limitations in how health information is captured and shared. Fax machines remain common, and patients often serve as couriers for their own paper records.

From an underwriting perspective, these challenges contribute directly to:

Delays in obtaining attending physician statements (APS)
Incomplete or outdated medical evidence
Greater reliance on applicant disclosure and paramedical summaries

For insurers more broadly, these challenges can translate into longer wait times and a more complex application experience for customers.

Bill S‑5 aims to address these issues by mandating interoperability standards for health information technology vendors and prohibiting “data blocking”—practices that hinder lawful data sharing.

Dossier santé numérique

This shift is also happening at the provincial level.² In Quebec, Santé Québec has started piloting its Dossier santé numérique, which brings together patient information—including test results, medications, and care plans—into a single digital record. It is another example of the broader move toward more connected and accessible health data across Canada.

Why does this matter?

As the life and living benefits market expands and customer expectations rise, there is growing pressure to make decisions faster and more efficiently. Insurers are keen to replace costly, time-consuming data sources, such as blood and urine samples and APS, with streamlined alternatives such as electronic health records (EHRs).

What is an Electronic Health Record (EHR)*?

An Electronic Health Record (EHR) is a secure, real-time, patient-centered digital record accessible to authorized users. EHRs are designed to facilitate information sharing among healthcare providers and represent a significant step forward from traditional paper charts. These records enable insurers to:

Enhance accuracy in risk assessment for underwriting
Improve underwriting efficiency and turnaround times
Reduce or eliminate the need for paramedical exams and lab tests in many cases

By leveraging EHRs, life insurers can shorten underwriting timelines, minimize delays, and rely less on fragmented or outdated information sources. Together, advances in technology and regulation could help the industry improve efficiency and respond to rising policyholder expectations.

*The term Electronic Health Record (EHR) is often used interchangeably with Electronic Medical Record (EMR). However, an EMR generally captures information from a single provider or data source, whereas EHRs are more comprehensive, designed to be used by multiple care providers and be interoperable across different systems.

Looking ahead: Practical implications

As legislation, such as Bill S‑5, begins to break down data silos, underwriters have the opportunity to access applicant health information more quickly and with fewer gaps. Improved interoperability could reduce redundant testing and paperwork, accelerate medical evidence collection, and support stronger risk assessment by making relevant records available sooner.

In recent years, Munich Re, Canada (Life) has worked with several organizations to enable the use of digital medical data, such as historical laboratory results and prescription histories, in Canadian underwriting. Bill S‑5 is important because it is intended to improve interoperability and reduce barriers to lawful data sharing. If implemented effectively, it could support more consistent retrieval of third-party evidence with less manual effort. However, the bill does not create unfettered access to health information; disclosure would still remain subject to applicant consent, privacy laws, and provincial health-information rules.

Bill S‑5 is still progressing through Parliament and, as of April 2026, had completed Senate committee review but had not yet reached the House of Commons. Life insurers should closely monitor regulatory consultations, as this legislation may bring about systemic changes affecting how underwriters access and assess risk-related information. EHRs will be instrumental in this evolution, helping the industry move beyond the limitations of the APS toward a more digital, streamlined future.

Munich Re will continue to closely monitor all developments on this important topic and will provide updates as they occur.