The Association of Canadian Early Learning Programs (ACE) recently released its Sustainable Framework for CWELCC, arguing that Ontario’s child care system requires significant reform to remain financially sustainable.

ACE identifies several real challenges facing the sector. Operators are struggling with workforce shortages, increasing costs, administrative complexity, and the difficulty of expanding licensed spaces quickly enough to meet demand.

Where B2C2 differs is not in recognizing these challenges, but in diagnosing their causes and proposing solutions.

ACE’s recommendations largely focus on managing demand, restricting eligibility, and restructuring affordability. B2C2 believes the central challenge facing Ontario’s child care system is different: Canada has successfully built an affordability system but has not yet built the infrastructure financing and workforce supports required to expand supply.

The question facing policymakers is therefore not whether CWELCC should serve fewer families, but how governments can create more spaces and recruit more educators.

Long waiting lists are not evidence that affordable child care has failed. They are evidence that Ontario has not yet built enough spaces to meet demand.

At its core, the difference between ACE’s framework and B2C2’s approach is straightforward. ACE’s recommendations focus largely on reducing demand for affordable child care through eligibility restrictions, targeted affordability, and system restructuring. B2C2’s recommendations focus on expanding the supply of affordable child care by addressing workforce shortages, infrastructure barriers, and financing challenges that prevent new spaces from being created.

1. Adopt a Tiered Affordability Model

The intention is understandable: directing limited public resources toward families perceived to need the greatest support. However, universal programs have important advantages. They are simpler to administer, avoid creating eligibility cliffs, and maintain broad public support.

Before CWELCC, child care affordability varied dramatically between communities and income groups. Many families paid fees comparable to a monthly mortgage payment. One of CWELCC’s greatest achievements has been replacing this fragmented system with a more predictable and equitable approach.

The question is whether Ontario should be rebuilding the very patchwork system it spent decades trying to overcome.

Rather than reducing access, governments should focus on expanding capacity so that all families who need licensed child care can obtain it.

2. Align Eligibility to Children Under Five

ACE proposes ending CWELCC eligibility when children enter Junior Kindergarten and repurposing those spaces for younger children.

This recommendation raises significant practical questions.

In many Ontario schools, kindergarten classrooms are used by JK and SK students during the school day and support before- and after-school programs outside instructional hours. These arrangements represent an efficient use of public infrastructure.

If kindergarten-age children are removed from CWELCC eligibility and school-based spaces are converted for preschool use, where will those children receive their kindergarten education and before- and after-school care?  How would school boards accommodate the resulting changes in space allocation? How many new spaces would actually be created?

Families do not stop needing child care when their children enter Junior Kindergarten. They continue to require before-school care, after-school care, PA day programs, holiday coverage, and summer care.

Most importantly, ACE provides limited evidence to demonstrate that the projected savings or space gains associated with this proposal would outweigh the resulting disruption to families, schools, and operators.

Before considering such a significant restructuring, policymakers should require transparent modelling, detailed implementation plans, and evidence demonstrating that the proposal would achieve its intended outcomes.

In effect, this proposal assumes that kindergarten space can simply be converted into preschool space. Yet kindergarten students do not disappear. School boards would still be required to provide kindergarten education and before-and-after-school care. The proposal appears to shift space pressures from one part of the system to another rather than creating meaningful new capacity.

Across Canada, most provinces do not offer full-day Junior Kindergarten. Four-year-olds typically receive care through licensed child care programs. Is ACE proposing that CWELCC support effectively end at age four for children across the country?

More importantly, families do not stop needing care when children enter school. They continue to require before- and after-school programs, PA day coverage, holiday programs, and summer care. Removing affordability supports at the point of school entry would simply shift costs back onto families while creating new pressures for schools and operators. That outcome appears inconsistent with CWELCC’s objective of supporting children and families from birth to age five.

3. Standardize Operating Grants

ACE proposes standardizing operating grants across the system.

While consistency and transparency are worthwhile objectives, standardization is not necessarily synonymous with fairness.

Ontario’s child care system serves communities with very different realities. Rural providers, urban providers, operators serving high-needs populations, and programs located in high-cost regions often face substantially different operating pressures.

Any proposal to standardize funding should answer a straightforward question: who gains, who loses, and how will service quality and access be protected?

Funding systems should reflect the actual costs of delivering high-quality child care rather than assuming all programs operate under identical circumstances.

Ontario has spent years moving toward a cost-based funding model that recognizes the actual cost of delivering high-quality child care. Replacing cost-based funding with standardized operating grants risks recreating the very funding inequities the current system was designed to address. Before any such change is considered, policymakers should clearly identify who benefits, who loses, and how service quality and access will be protected.

4. Restore Targeted Workforce Stabilization

ACE correctly identifies workforce challenges as one of the most significant barriers facing the sector.

B2C2 agrees.

The shortage of qualified educators continues to limit expansion across Ontario. Many operators have the physical capacity to grow but cannot recruit and retain sufficient staff.

Where we differ is in the scope of the solution.

Workforce stabilization requires more than temporary measures. It requires long-term investment in compensation, benefits, professional recognition, and the full implementation of pay equity obligations. Funding formulas must recognize that fair wages are not optional costs to be absorbed by operators. They are public policy responsibilities within a publicly funded system.

If governments want more child care spaces, they must ensure qualified educators are available to staff them.

The workforce challenge is not evidence that affordability has gone too far. It is evidence that public funding has not yet fully addressed compensation, benefits, career pathways, and pay equity obligations necessary to attract and retain educators.

5. Enable Performance-Based Expansion

Accountability matters. Public funding should support high-quality programs that effectively serve families.

However, performance-based expansion raises important questions.

How will performance be measured? Will criteria focus on quality, inclusion, workforce retention, occupancy, financial management, or some combination of factors? Will smaller operators and providers serving vulnerable communities be disadvantaged by measures that favour organizations with greater resources?

Expansion policy should prioritize community needs over performance. Otherwise, underserved communities may continue to face limited access despite having the greatest demand. Expansion should be driven first by community need, not solely by an organization’s ability to meet performance metrics. Otherwise, communities with the greatest shortages may continue to be underserved.

Also, expansion is not limited to child care centres.  Many community, faith-based, Indigenous and cultural organizations should have the opportunity to create child care for their communities.  ACE suggests that expansion should only be considered by existing child care programs.

6. Establish a Funded Non-RECE Wage Floor

Non-RECE staff play essential roles in child care programs, yet compensation often remains inadequate.

B2C2 supports efforts to improve compensation for all child care workers. Child care quality depends heavily on a qualified workforce. Ontario has invested significantly in RECE training and professional standards because educator qualifications matter. Any workforce strategy should improve compensation for non-RECE staff while maintaining incentives for recruitment, retention, and professional development of RECEs. The objective should be a comprehensive workforce strategy that supports recruitment, retention, professional development, and fair compensation for both RECE and non-RECE staff.

Evidence Matters

Public policy decisions affecting hundreds of thousands of children, families, and educators should be grounded in transparent evidence.

ACE’s framework includes projections related to system savings, affordability reforms, eligibility changes, and expansion outcomes. However, many of these projections are not accompanied by detailed references, published methodologies, or transparent modelling assumptions. In several instances, the report refers generally to “AI analysis” and publicly available data sources without providing sufficient detail for readers to independently assess how conclusions were reached.

This matters because policy recommendations are only as strong as the evidence supporting them. If significant changes to CWELCC are being proposed, policymakers should be able to examine the underlying assumptions, test alternative scenarios, and evaluate potential impacts on families, operators, educators, and communities.

B2C2 believes that major reforms should be supported by transparent research, clearly cited sources, and publicly available modelling. The discussion should focus not only on projected savings, but also on the broader economic, social, and workforce impacts of proposed changes.

The Real Challenge: Expansion

ACE and B2C2 agree on one important point: Ontario’s child care system faces serious challenges. The preceding discussion illustrates a fundamental difference in perspective. ACE’s framework focuses primarily on managing demand within the existing system. B2C2’s approach focuses on expanding the system itself.

Where we disagree is on the solution.

ACE’s framework focuses primarily on reducing demand pressures and limiting eligibility.

B2C2 believes the central challenge is insufficient supply.

Ontario currently has nearly 300,000 children enrolled in licensed child care and at least 144,000 children on waiting lists. These waiting lists are not evidence that CWELCC has failed. They are evidence that families want affordable child care and that governments have not yet built enough spaces to meet demand.

The path forward is not to reduce access. It is to complete the system that governments have already committed to building.

That means investing in educator compensation, implementing child care infrastructure financing tools, supporting non-profit expansion, and creating the physical capacity needed to serve more families.

B2C2 has consistently argued that expansion requires three things:

• a renewed long-term federal-provincial CWELCC agreement,
• implementation of the federal child care expansion financing program announced in Budget 2024, and

he development of additional infrastructure financing tools that allow non-profit providers to build and expand facilities. These measures address the actual barriers to growth rather than reducing access for families.

The evidence increasingly suggests that affordable child care works. Parent fees have fallen, labour force participation has increased, and demand for licensed care continues to grow.

The challenge facing governments is not whether CWELCC should serve fewer families. The challenge is whether governments are prepared to complete the system they have already committed to building.

Nor is the challenge that affordability has gone too far. The challenge is that governments have not yet made the workforce and infrastructure investments required to support expansion.

That means renewing long-term CWELCC agreements, investing in educator compensation and pay equity, implementing child care infrastructure financing programs, and creating the physical capacity needed to expand non-profit and public child care across Ontario and Canada.

The debate is no longer about whether affordable child care is worth building.

The debate is whether governments are prepared to finish the job.