--- title: "Canada — Global AI Monitor" canonical: https://artificial-intelligence.gi/jurisdictions/canada/ source_html: /jurisdictions/canada/index.html description: "Canada AI governance record: 8 instruments, 0 obligations and 40 evidenced claims across 12 modules. Research as of 12 Nov 2026." generated_at: 2026-11-12T17:20:02Z content_sha256: c9f4b71a1a1a320dcc46c08ebeaa560f46346d4496f7562b271f37dbff61cad6 generator: "fe-fleet/md-twin@1.0" --- # Canada AI Regulation & Governance 10 active modules 2 quiet Last updated 11 Nov 2026 · 12 modules · 8 instruments · 40 claims · 39 sources in the cumulative register Download report (PDF) Collapse all Framework status Bill-C-36-45-1 (Draft, no legal force). Main regulator Regulator [Canadian Artificial Intelligence Safety Institute (CAISI) at ISED; Minister of AI and Digital Innovation — no statutory AI regulator](https://ised-isde.canada.ca/site/ised/en/canadian-artificial-intelligence-safety-institute) Next milestone No upcoming dated milestone recorded Record status Live · Periodic active record · 39 sources (33 retrieved) · 14 under review · Not yet expert-reviewed ✦ AI-assembled from cited sources Evidence-gated · [How we verify](/methodology/#ai-content-disclosure) · Disclosure Not yet expert-reviewed · Not legal, compliance or investment advice. Facts are machine-assembled from cited public sources. Individual claims have not each been independently verified by a human reviewer. See [methodology](/methodology/). Source tiers: T1 enacted statute, regulation, or binding supervisory order · T2 official regulator guidance, consultation, or registry · T3 international standard-setter or peer-reviewed analysis · T4 practitioner commentary or secondary reporting. Confidence: high = corroborated by retrieved T1/T2 text · medium = single official source or secondary corroboration · low = preliminary or unverified. [Full definitions →](/methodology/#source-tiers) Research checked 12 Nov 2026 · Updated 11 Nov 2026 Record history Research as of 12 Nov 2026 · Record last changed 11 Nov 2026 · Published 11 Nov 2026 · Page built 12 Nov 2026 8 Instruments 6 Current instruments 1 Binding, in force 0 Obligations 40 Claims 0 Upcoming milestones 39 Sources Jump to module (12) ### 01AI Framework LawActive Derived: Probable▾# Bill-C-36-45-1 (Draft, no legal force). 2 instruments (1 current) · 0 obligations · 8 claims · 0 milestones Canada has no horizontal AI statute currently in force. The Artificial Intelligence and Data Act, which formed Part 3 of Bill C-27 and would have created Canada's first comprehensive private-sector AI statute, died on the Order Paper when Parliament was prorogued on 6 January 2025, and as of the run date no successor federal AI act had been introduced. In the absence of a dedicated AI statute, binding obligations touching automated decision-making arise instead from provincial law. Article 12.1 of Quebec's Act respecting the protection of personal information in the private sector, as amended by Law 25, requires an enterprise that renders a decision based exclusively on automated processing of personal information to inform the individual concerned and to allow them to submit observations. At the non-binding level, Innovation, Science and Economic Development Canada's Voluntary Code of Conduct on the Responsible Development and Management of Advanced Generative AI Systems, effective from 27 September 2023, commits signatory developers and managers of advanced generative AI systems to risk-management measures but creates no statutory obligation and binds only its signatories. A further legislative vehicle touching AI-adjacent data protection, Bill C-36 (Protecting Privacy and Consumer Data Act), which would repeal Part 1 of the Personal Information Protection and Electronic Documents Act and create the Digital Safety and Data Protection Commission of Canada, had its first reading on 15 June 2026 and remained pending second reading as of the run date; it has not been enacted. Read full sub-brief · 241 words Instruments (2) - Bill-C-36-45-1 Draft, no legal force - Artificial Intelligence and Data Act (AIDA), Part 3 of Bill C-27 Ended 2025-01-06 Not currentDraft, no legal force Claims and evidence (8) - ISED's Voluntary Code of Conduct on the Responsible Development and Management of Advanced Generative AI Systems, effective from 27 September 2023, commits signatory developers and managers of advanced generative AI systems to risk-management measures but creates no statutory obligation.Confidence: Probable · As of 27 Sep 2023 · EvidencedEvidence and sources[Innovation, Science and Economic Development Canada](https://ised-isde.canada.ca/site/ised/en/voluntary-code-conduct-responsible-development-and-management-advanced-generative-ai-systems) T1 · Retrieved · retrieved 27 Sep 2023many of the measures are broadly applicable to a range of high-impact AI systems and can be readily adapted - [Innovation, Science and Economic Development Canada](https://www.canada.ca/en/innovation-science-economic-development/news/2023/09/minister-champagne-launches-voluntary-code-of-conduct-relating-to-advanced-generative-ai-systems.html) T1 · Retrievedannounced Canada's Voluntary Code of Conduct on the Responsible Development and Management of Advanced Generative AI Systems - Derived: Probable Canada's proposed horizontal AI statute, the Artificial Intelligence and Data Act (Part 3 of Bill C-27), died when Parliament was prorogued on 6 January 2025, and no successor AI act had been introduced federally as at the run date.Confidence: Probable · EvidencedEvidence and sources[sanitized.ai](https://sanitized.ai/standards/aida-bill-c-27/) T3 · Retrieved · retrieved 4 Nov 2026Canada's proposed AI law died when Parliament was prorogued in January 2025, and no successor AI act has been - [Lexpert](https://www.lexpert.ca/news/technology-law/ai-laws-update-what-now-after-artificial-intelligence-and-data-act/394712) T2 · Retrieved · retrieved 2 Nov 2026Manitoba's Public Sector Artificial Intelligence and Cybersecurity Governance Act received Royal Assent in June 2026. - Derived: Probable AIDA (Part 3 of Bill C-27), which would have created Canada's first comprehensive private-sector AI statute, died on the Order Paper when Parliament was prorogued on 6 January 2025, and as of the run date no successor AI act had been introduced.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[sanitized.ai](https://sanitized.ai/standards/aida-bill-c-27/) T3 · Retrieved · retrieved 4 Nov 2026Canada's proposed AI law died when Parliament was prorogued in January 2025, and no successor AI act has been - Derived: Probable Under article 12.1 of Quebec's Act respecting the protection of personal information in the private sector, as amended by Law 25, an enterprise that renders a decision based exclusively on automated processing of personal information must inform the individual concerned and allow them to submit observations.Confidence: Probable (capped: best source is T1) · EvidencedEvidence and sources[Éditeur officiel du Québec](https://www.legisquebec.gouv.qc.ca/fr/document/lc/p-39.1) T1 · Surfaced · retrieved 4 Nov 2026Any person who operates an enterprise and uses personal information in order to render a decision based - [Borden Ladner Gervais LLP](https://www.blg.com/-/media/insights/documents/blg-quebec-bill-64-october-guide3.pdf) T3 · Retrieveda "person designated by the Commission, but who is not a member of any of its divisions" will have - Bill C-36 (Protecting Privacy and Consumer Data Act), which would repeal PIPEDA Part 1 and create the Digital Safety and Data Protection Commission of Canada, had its first reading on 15 June 2026 and remained pending second reading as of the run date.Confidence: Probable · EvidencedEvidence and sources[Parliament of Canada (LEGISinfo)](https://www.parl.ca/legisinfo/en/bill/45-1/c-36) T1 · RetrievedIntroduction and first reading on Monday, June 15, 2026 (House of Commons) - Derived: Probable Canada's proposed Artificial Intelligence and Data Act (AIDA) died on the Order Paper when Parliament was prorogued on 6 January 2025, and no successor AI statute has been introduced, so Canada has no horizontal AI statute in force.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[sanitized.ai](https://sanitized.ai/standards/aida-bill-c-27/) T3 · Retrieved · retrieved 4 Nov 2026Canada's proposed AI law died when Parliament was prorogued in January 2025, and no successor AI act has been - AIDA (Bill C-27 Part 3) died on prorogation on 6 January 2025 and no successor horizontal AI statute has been introduced.Confidence: Probable (capped: best source is T3) · As of 6 Jan 2025 · EvidencedEvidence and sources[sanitized.ai](https://sanitized.ai/standards/aida-bill-c-27/) T3 · Retrieved · retrieved 4 Nov 2026Canada's proposed AI law died when Parliament was prorogued in January 2025, and no successor AI act has been - Derived: Probable AIDA (Bill C-27 Part 3) died on the Order Paper when Parliament was prorogued on 6 January 2025, and no successor AI act has been introduced.Confidence: Probable (capped: best source is T3) · As of 6 Jan 2025 · EvidencedEvidence and sources[sanitized.ai](https://sanitized.ai/standards/aida-bill-c-27/) T3 · Retrieved · retrieved 4 Nov 2026Canada's proposed AI law died when Parliament was prorogued in January 2025, and no successor AI act has been ### 02Prohibited PracticesActive Derived: Probable▾# AIDA (Part 3 of Bill C-27), which would have created Canada's first comprehensive private-sector AI statute, died on the Order Paper when Parliament was prorogued on 6 January 2025, and as of the run date no successor AI act had been introduced. 1 instrument (0 current) · 0 obligations · 3 claims · 0 milestones Manitoba has enacted an amendment to its Business Practices Act, receiving Royal Assent on 1 June 2026, that, according to available reporting, prohibits personalized algorithmic pricing directed at Manitoba consumers without their consent. No federal prohibited-practices regime specific to AI exists. The Artificial Intelligence and Data Act (Part 3 of Bill C-27), which would have created such a framework, died on the Order Paper when Parliament was prorogued on 6 January 2025, and no successor AI act has been introduced. Instruments (1) - Artificial Intelligence and Data Act (AIDA), Part 3 of Bill C-27 Ended 2025-01-06 Not currentDraft, no legal force Claims and evidence (3) - Derived: Probable AIDA (Part 3 of Bill C-27), which would have created Canada's first comprehensive private-sector AI statute, died on the Order Paper when Parliament was prorogued on 6 January 2025, and as of the run date no successor AI act had been introduced.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[sanitized.ai](https://sanitized.ai/standards/aida-bill-c-27/) T3 · Retrieved · retrieved 4 Nov 2026Canada's proposed AI law died when Parliament was prorogued in January 2025, and no successor AI act has been - Derived: Probable AIDA (Bill C-27 Part 3) died on the Order Paper when Parliament was prorogued on 6 January 2025, and no successor AI act has been introduced.Confidence: Probable (capped: best source is T3) · As of 6 Jan 2025 · EvidencedEvidence and sources[sanitized.ai](https://sanitized.ai/standards/aida-bill-c-27/) T3 · Retrieved · retrieved 4 Nov 2026Canada's proposed AI law died when Parliament was prorogued in January 2025, and no successor AI act has been - Manitoba prohibited personalized algorithmic pricing toward Manitoba consumers without consent under an amendment to the Business Practices Act, Royal Assent 1 June 2026.Confidence: Uncertain (Capped from Probable: best source is T4) · As of 1 Jun 2026 · EvidencedEvidence and sources[Mondaq](https://www.mondaq.com/canada/new-technology/1801730/manitoba-introduces-algorithmic-pricing-and-public-sector-ai-regulation) T4 · Surfaced · retrieved 4 Nov 2026Manitoba has prohibited the use of personalized algorithmic pricing for Manitoba consumers without their consent ### 03High-Risk SystemsActive Derived: Probable▾# Act respecting the protection of personal information in the private sector (Quebec) (In force since 2023-09-22). 3 instruments (2 current) · 0 obligations · 9 claims · 0 milestones Quebec's Law 25 amendment to the Act respecting the protection of personal information in the private sector has required, since 22 September 2023, that an enterprise notify an individual when a decision concerning them is made exclusively through automated processing of personal information, under article 12.1, and that it allow the individual to submit observations and request a review. At the federal level, the Treasury Board Secretariat's Directive on Automated Decision-Making, in effect since 1 April 2019, requires a federal institution to complete and release an Algorithmic Impact Assessment classifying an automated decision system into one of four impact levels, with scaled mitigation requirements, before the system is placed into production, and to give affected individuals notice of automation, publish an explanation, and provide recourse proportional to the assessed impact level. Existing federal automated decision systems developed or procured before 24 June 2025 have until 24 June 2026 to comply with the Directive's updated requirements. A joint investigation by the federal Privacy Commissioner together with Quebec's Commission d'accès à l'information and the British Columbia and Alberta privacy commissioners, reported as PIPEDA Findings #2026-002, found that an AI provider's usage policies do not permit automating high-stakes decisions in employment, financial or essential government-service contexts. No federal high-risk-systems statute is in force: the Artificial Intelligence and Data Act (Part 3 of Bill C-27), which would have introduced dedicated obligations for high-impact AI systems, died on the Order Paper when Parliament was prorogued on 6 January 2025, and no successor AI act has been introduced. Read full sub-brief · 252 words Instruments (3) - Act respecting the protection of personal information in the private sector (Quebec) In force since 2023-09-22Binding - Directive on Automated Decision-Making In force since 2019-04-01Regulatory expectation - Artificial Intelligence and Data Act (AIDA), Part 3 of Bill C-27 Ended 2025-01-06 Not currentDraft, no legal force Claims and evidence (9) - Derived: Probable AIDA (Part 3 of Bill C-27), which would have created Canada's first comprehensive private-sector AI statute, died on the Order Paper when Parliament was prorogued on 6 January 2025, and as of the run date no successor AI act had been introduced.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[sanitized.ai](https://sanitized.ai/standards/aida-bill-c-27/) T3 · Retrieved · retrieved 4 Nov 2026Canada's proposed AI law died when Parliament was prorogued in January 2025, and no successor AI act has been - Derived: Probable Existing federal automated decision systems developed or procured prior to 24 June 2025 have until 24 June 2026 to comply with the updated requirements of the Directive on Automated Decision-Making.Confidence: Probable · EvidencedEvidence and sources[Treasury Board of Canada Secretariat](https://www.tbs-sct.canada.ca/pol/doc-eng.aspx?id=32592) T1 · Retrieved · retrieved 4 Nov 2026Existing automated decision systems developed or procured prior to June 24, 2025, will have until June 24, 2026 - Derived: Probable Under article 12.1 of Quebec's Act respecting the protection of personal information in the private sector, as amended by Law 25, an enterprise that renders a decision based exclusively on automated processing of personal information must inform the individual concerned and allow them to submit observations.Confidence: Probable (capped: best source is T1) · EvidencedEvidence and sources[Éditeur officiel du Québec](https://www.legisquebec.gouv.qc.ca/fr/document/lc/p-39.1) T1 · Surfaced · retrieved 4 Nov 2026Any person who operates an enterprise and uses personal information in order to render a decision based - [Borden Ladner Gervais LLP](https://www.blg.com/-/media/insights/documents/blg-quebec-bill-64-october-guide3.pdf) T3 · Retrieveda "person designated by the Commission, but who is not a member of any of its divisions" will have - Derived: Probable A joint investigation by Canada's federal Privacy Commissioner with Quebec's CAI and the British Columbia and Alberta commissioners (PIPEDA Findings #2026-002) found that OpenAI's usage policies do not permit automating high-stakes decisions in employment, financial or essential government-service contexts without human review, but do not affirmatively prohibit using its outputs to support decision-making in those areas.Confidence: Confirmed · EvidencedEvidence and sources[Office of the Privacy Commissioner of Canada](https://www.priv.gc.ca/en/opc-actions-and-decisions/investigations/investigations-into-businesses/2026/pipeda-2026-002/) T1 · Retrieved · retrieved 4 Nov 2026OpenAI's policies do not permit the automation of high-stakes decisions in sensitive areas (such as employment, financial activities - The Directive on Automated Decision-Making requires a federal institution to complete and release an Algorithmic Impact Assessment, classifying the automated decision system into one of four impact levels with scaled mitigation requirements, before the system goes into production.Confidence: Probable · EvidencedEvidence and sources[regulations.ai](https://regulations.ai/regulations/canada-2019-3-directive-automated-decision-making) T4 · Retrieved · retrieved 4 Nov 2026mandates Algorithmic Impact Assessments and human oversight for federal institutions using automated decision systems - [Treasury Board of Canada Secretariat](https://www.canada.ca/en/government/system/digital-government/digital-government-innovations/responsible-use-ai/automated-decision-making/guide-scope-directive-automated-decision-making.html) T1 · Retrieved · retrieved 27 Jun 2024The automated decision systems could use rules, regression, advanced analytics, AI, generative AI, machine learning, neural networks - Derived: Probable AIDA (Bill C-27 Part 3) died on the Order Paper when Parliament was prorogued on 6 January 2025, and no successor AI act has been introduced.Confidence: Probable (capped: best source is T3) · As of 6 Jan 2025 · EvidencedEvidence and sources[sanitized.ai](https://sanitized.ai/standards/aida-bill-c-27/) T3 · Retrieved · retrieved 4 Nov 2026Canada's proposed AI law died when Parliament was prorogued in January 2025, and no successor AI act has been - Federal institutions must complete an Algorithmic Impact Assessment before putting an automated decision system into production, under the Directive on Automated Decision-Making.Confidence: Uncertain (Capped from Probable: best source is T4) · As of 1 Apr 2019 · EvidencedEvidence and sources[regulations.ai](https://regulations.ai/regulations/canada-2019-3-directive-automated-decision-making) T4 · Retrieved · retrieved 4 Nov 2026mandates Algorithmic Impact Assessments and human oversight for federal institutions using automated decision systems - The Directive on Automated Decision-Making requires institutions to give affected individuals notice of automation, publish an explanation, and provide recourse proportional to impact level.Confidence: Uncertain (Capped from Probable: best source is T4) · As of 1 Apr 2019 · EvidencedEvidence and sources[PACMap](https://pacmap.dev/regulation/ca-dadm-2019) T4 · Retrieved · retrieved 4 Nov 2026Provide affected individuals with notice that decisions are automated and mechanisms for recourse or appeal - Quebec's Law 25 (art. 12.1), in force since 22 September 2023, requires an enterprise to notify an individual when a decision about them is made exclusively through automated processing and to allow a review request.Confidence: Probable · As of 22 Sep 2023 · EvidencedEvidence and sources[Éditeur officiel du Québec](https://www.legisquebec.gouv.qc.ca/fr/document/lc/p-39.1) T1 · Surfaced · retrieved 4 Nov 2026Any person who operates an enterprise and uses personal information in order to render a decision based ### 04General-Purpose AIActive Derived: Probable▾# Voluntary Code of Conduct on the Responsible Development and Management of Advanced Generative AI Systems (In force since 2023-09-27). 2 instruments (1 current) · 0 obligations · 6 claims · 0 milestones Innovation, Science and Economic Development Canada's Voluntary Code of Conduct on the Responsible Development and Management of Advanced Generative AI Systems has applied since 27 September 2023. It commits signatory developers and managers of advanced generative AI systems to risk-management measures spanning safety testing, accountability, transparency, fairness and equity, human oversight and validity, but it creates no statutory obligation and binds only its signatories. ISED has stated that many of the Code's measures are broadly applicable to a range of high-impact AI systems and can be readily adapted beyond generative AI. No federal statute specifically governing general-purpose or foundation AI models is in force: the Artificial Intelligence and Data Act (Part 3 of Bill C-27), which would have introduced obligations covering high-impact AI systems, died on the Order Paper when Parliament was prorogued on 6 January 2025, and no successor AI act has been introduced. Instruments (2) - Voluntary Code of Conduct on the Responsible Development and Management of Advanced Generative AI Systems In force since 2023-09-27Non-binding - Artificial Intelligence and Data Act (AIDA), Part 3 of Bill C-27 Ended 2025-01-06 Not currentDraft, no legal force Claims and evidence (6) - ISED's Voluntary Code of Conduct on the Responsible Development and Management of Advanced Generative AI Systems, effective from 27 September 2023, commits signatory developers and managers of advanced generative AI systems to risk-management measures but creates no statutory obligation.Confidence: Probable · As of 27 Sep 2023 · EvidencedEvidence and sources[Innovation, Science and Economic Development Canada](https://ised-isde.canada.ca/site/ised/en/voluntary-code-conduct-responsible-development-and-management-advanced-generative-ai-systems) T1 · Retrieved · retrieved 27 Sep 2023many of the measures are broadly applicable to a range of high-impact AI systems and can be readily adapted - [Innovation, Science and Economic Development Canada](https://www.canada.ca/en/innovation-science-economic-development/news/2023/09/minister-champagne-launches-voluntary-code-of-conduct-relating-to-advanced-generative-ai-systems.html) T1 · Retrievedannounced Canada's Voluntary Code of Conduct on the Responsible Development and Management of Advanced Generative AI Systems - Derived: Probable AIDA (Part 3 of Bill C-27), which would have created Canada's first comprehensive private-sector AI statute, died on the Order Paper when Parliament was prorogued on 6 January 2025, and as of the run date no successor AI act had been introduced.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[sanitized.ai](https://sanitized.ai/standards/aida-bill-c-27/) T3 · Retrieved · retrieved 4 Nov 2026Canada's proposed AI law died when Parliament was prorogued in January 2025, and no successor AI act has been - ISED's Voluntary Code of Conduct on the Responsible Development and Management of Advanced Generative AI Systems, effective from 27 September 2023, commits signatory developers and managers of advanced generative AI systems to risk measures but creates no statutory obligation and binds only signatories.Confidence: Probable · EvidencedEvidence and sources[Osler, Hoskin & Harcourt LLP](https://www.osler.com/en/insights/updates/ised-s-voluntary-code-of-conduct-on-the-responsible-development-and-management-of-advanced-generativ/) T3 · Retrievedthe Code of Conduct is a set of voluntary commitments intended to commit developers and managers of advanced generative systems - [Innovation, Science and Economic Development Canada](https://ised-isde.canada.ca/site/ised/en/voluntary-code-conduct-responsible-development-and-management-advanced-generative-ai-systems) T1 · Retrieved · retrieved 27 Sep 2023many of the measures are broadly applicable to a range of high-impact AI systems and can be readily adapted - ISED's Voluntary Code of Conduct on advanced generative AI is a non-binding instrument in force since 27 September 2023, binding only its signatories.Confidence: Probable · As of 27 Sep 2023 · EvidencedEvidence and sources[Innovation, Science and Economic Development Canada](https://ised-isde.canada.ca/site/ised/en/voluntary-code-conduct-responsible-development-and-management-advanced-generative-ai-systems) T1 · Retrieved · retrieved 27 Sep 2023many of the measures are broadly applicable to a range of high-impact AI systems and can be readily adapted - [Osler, Hoskin & Harcourt LLP](https://www.osler.com/en/insights/updates/ised-s-voluntary-code-of-conduct-on-the-responsible-development-and-management-of-advanced-generativ/) T3 · Retrievedthe Code of Conduct is a set of voluntary commitments intended to commit developers and managers of advanced generative systems - Derived: Probable AIDA (Bill C-27 Part 3) died on the Order Paper when Parliament was prorogued on 6 January 2025, and no successor AI act has been introduced.Confidence: Probable (capped: best source is T3) · As of 6 Jan 2025 · EvidencedEvidence and sources[sanitized.ai](https://sanitized.ai/standards/aida-bill-c-27/) T3 · Retrieved · retrieved 4 Nov 2026Canada's proposed AI law died when Parliament was prorogued in January 2025, and no successor AI act has been - ISED's Voluntary Code of Conduct, effective 27 September 2023, commits signatory developers/managers of advanced generative AI systems to risk measures but creates no statutory obligation.Confidence: Probable · As of 27 Sep 2023 · EvidencedEvidence and sources[Innovation, Science and Economic Development Canada](https://ised-isde.canada.ca/site/ised/en/voluntary-code-conduct-responsible-development-and-management-advanced-generative-ai-systems) T1 · Retrieved · retrieved 27 Sep 2023many of the measures are broadly applicable to a range of high-impact AI systems and can be readily adapted ### 05Transparency & Synthetic ContentActive Derived: Probable▾# AIDA (Bill C-27 Part 3) died on the Order Paper when Parliament was prorogued on 6 January 2025, and no successor AI act has been introduced. 1 instrument (0 current) · 0 obligations · 1 claim · 0 milestones Canada has no binding transparency or synthetic-content-labelling statute for AI systems. The Artificial Intelligence and Data Act (Part 3 of Bill C-27), which would have introduced transparency-related obligations for high-impact AI systems, died on the Order Paper when Parliament was prorogued on 6 January 2025, and no successor AI act has been introduced as of the run date. Instruments (1) - Artificial Intelligence and Data Act (AIDA), Part 3 of Bill C-27 Ended 2025-01-06 Not currentDraft, no legal force Claims and evidence (1) - Derived: Probable AIDA (Bill C-27 Part 3) died on the Order Paper when Parliament was prorogued on 6 January 2025, and no successor AI act has been introduced.Confidence: Probable (capped: best source is T3) · As of 6 Jan 2025 · EvidencedEvidence and sources[sanitized.ai](https://sanitized.ai/standards/aida-bill-c-27/) T3 · Retrieved · retrieved 4 Nov 2026Canada's proposed AI law died when Parliament was prorogued in January 2025, and no successor AI act has been ### 06AI & Intellectual PropertyQuiet▾# Nothing recorded for this module in the research of 2026-11-12. 0 instruments · 0 obligations · 0 claims Nothing recorded for this module in the research of 2026-11-12. ### 07Sectoral & Public-Sector AIActive Derived: Probable▾# Directive on Automated Decision-Making (In force since 2019-04-01). 3 instruments (3 current) · 0 obligations · 19 claims · 0 milestones Ontario's Enhancing Digital Security and Trust Act has been in force since 29 January 2025, but its core framework's four AI-specific duties remain inoperative because no regulation prescribing the covered AI uses or the public-sector entities bound by them had been made as of the run date. Manitoba's Public Sector Artificial Intelligence and Cybersecurity Governance Act received Royal Assent on 1 June 2026 but was not yet in force as of the run date, pending proclamation and implementing regulations; it will apply to prescribed public-sector entities and to AI systems used in prescribed circumstances, with its substantive transparency and accountability content left to regulations not yet made. In a related measure, Manitoba also enacted an amendment to its Business Practices Act, with Royal Assent on 1 June 2026, that, according to available reporting, prohibits personalized algorithmic pricing directed at Manitoba consumers without their consent. The Office of the Superintendent of Financial Institutions published its final Guideline E-23 on Model Risk Management on 11 September 2025, extending model-risk governance expectations to all models used by federally regulated financial institutions, including AI, machine learning and generative AI tools, and requiring an enterprise-wide model inventory and risk-based governance; the guideline takes effect on 1 May 2027. At the federal level, the Treasury Board Secretariat's Directive on Automated Decision-Making applies to automated decision systems in production that federal institutions use to make or assist administrative decisions, excluding research and test-environment systems, and requires a federal institution to complete an Algorithmic Impact Assessment before putting such a system into production. Existing federal automated decision systems have until 24 June 2026 to comply with the Directive's updated requirements. The Government of Canada published a minimum-viable-product AI transparency register disclosing federal AI systems on 28 November 2025, followed by a What We Heard Report on the register in September 2026. Read full sub-brief · 303 words Instruments (3) - Directive on Automated Decision-Making In force since 2019-04-01Regulatory expectation - Guideline E-23 – Model Risk Management (2027) Applies from 2027-05-01Regulatory expectation - Public Sector Artificial Intelligence and Cybersecurity Governance Act (Manitoba) Draft, no legal force Claims and evidence (19) - Derived: Probable OSFI's Guideline E-23 on Model Risk Management, published 11 September 2025, extends model-risk governance expectations explicitly to AI/ML models used by federally regulated financial institutions and takes effect 1 May 2027.Confidence: Confirmed · EvidencedEvidence and sources[Office of the Superintendent of Financial Institutions (OSFI)](https://www.osfi-bsif.gc.ca/en/news/backgrounder-guideline-e-23-model-risk-management) T1 · Retrieved · retrieved 11 Nov 2026sets out OSFI's expectations for how federally regulated financial institutions should manage risks associated with the use of models. - [McMillan LLP](https://mcmillan.ca/insights/publications/model-risk-governance-for-financial-institutions-new-guidance-for-a-new-era/) T3 · SurfacedOn September 11, 2025, the Office of the Superintendent of Financial Institutions ("OSFI") released Guideline E-23 - [Blakes](https://www.blakes.com/insights/osfi-releases-final-guideline-e-23-for-model-risk-management-and-ai-use-by-frfis/) T3 · Retrieved · retrieved 11 Nov 2026The Final Guideline, which will take effect on May 1, 2027, addresses emerging technology risks and imposes - Derived: Probable Manitoba's Public Sector Artificial Intelligence and Cybersecurity Governance Act received Royal Assent on 1 June 2026 but was not yet in force as of the run date, pending proclamation and implementing regulations.Confidence: Probable · EvidencedEvidence and sources[Fillmore Riley LLP](https://www.fillmoreriley.com/publication/manitoba's-new-ai-and-cybersecurity-governance-framework-for-the-public-sector) T3 · Retrieved · retrieved 4 Nov 2026The Act received Royal Assent on June 1, 2026, but is not yet in force. - [Government of Manitoba / Queen's Printer](https://web2.gov.mb.ca/laws/statutes/2026/c04326.php?lang=en) T1 · Retrieved · retrieved 1 Jun 2026This Act applies to prescribed public sector entities. - Derived: Probable Although Ontario's Enhancing Digital Security and Trust Act's core framework took effect on 29 January 2025, no regulation prescribing the AI uses or public-sector entities bound by it had been made as of the run date, leaving its four AI duties inoperative in practice.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[fruggr.io](https://www.fruggr.io/en/ontario-bill-194-ai-public-sector-rules-2026/) T3 · RetrievedBill 194's AI duties (disclosure, accountability framework, risk management, human oversight) are a frame; they bind only when - [McCarthy Tétrault LLP](https://www.mccarthy.ca/en/insights/blogs/techlex/ontario-bill-194-strengthening-cyber-security-and-building-trust-in-the-public-sector) T3 · Surfacedthe EDST creates requirements to comply but rules out the establishment of a private law duty of care - The federal Directive on Automated Decision-Making applies to automated decision systems in production used by federal institutions to make or assist administrative decisions, excluding research and test-environment systems.Confidence: Probable · As of 27 Jun 2024 · EvidencedEvidence and sources[Treasury Board of Canada Secretariat](https://www.canada.ca/en/government/system/digital-government/digital-government-innovations/responsible-use-ai/automated-decision-making/guide-scope-directive-automated-decision-making.html) T1 · Retrieved · retrieved 27 Jun 2024The automated decision systems could use rules, regression, advanced analytics, AI, generative AI, machine learning, neural networks - [Treasury Board of Canada Secretariat](https://www.tbs-sct.canada.ca/pol/doc-eng.aspx?id=32592) T1 · Retrieved · retrieved 4 Nov 2026Existing automated decision systems developed or procured prior to June 24, 2025, will have until June 24, 2026 - Derived: Probable OSFI's final Guideline E-23 on Model Risk Management, taking effect 1 May 2027, captures all models used by federally regulated financial institutions, including AI, machine learning and generative AI tools, and requires enterprise-wide model inventory and risk-based governance.Confidence: Probable (capped: best source is T3) · As of 11 Sep 2025 · EvidencedEvidence and sources[Torys LLP](https://www.torys.com/en/our-latest-thinking/publications/2025/10/osfi-updates-and-expands-scope-of-guideline-e-23) T3 · Retrieved · retrieved 2 Nov 2026All models are captured by the Guideline, regardless of their purpose or the materiality of their risk - [Borden Ladner Gervais LLP](https://www.blg.com/en/insights/2025/11/osfi-responds-to-the-growing-use-of-ai-key-updates-to-guideline-e-23) T3 · Retrieved · retrieved 2 Nov 2026must develop risk-based policies and procedures for model use that are proportional to their size, risk profile, complexity - [Blakes](https://www.blakes.com/insights/osfi-releases-final-guideline-e-23-for-model-risk-management-and-ai-use-by-frfis/) T3 · Retrieved · retrieved 11 Nov 2026The Final Guideline, which will take effect on May 1, 2027, addresses emerging technology risks and imposes - Derived: Probable Manitoba's Public Sector Artificial Intelligence and Cybersecurity Governance Act applies to prescribed public sector entities and AI systems used in prescribed circumstances, with substantive transparency and accountability content left to regulations not yet made.Confidence: Probable · As of 1 Jun 2026 · EvidencedEvidence and sources[Government of Manitoba / Queen's Printer](https://web2.gov.mb.ca/laws/statutes/2026/c04326.php?lang=en) T1 · Retrieved · retrieved 1 Jun 2026This Act applies to prescribed public sector entities. - [Torys LLP](https://www.torys.com/our-latest-thinking/publications/2026/06/manitoba-introduces-algorithmic-pricing-and-public-sector-ai-regulation) T3 · Retrieved · retrieved 4 Nov 2026Entities subject to the Act will be required to be transparent about their use of such systems - [Lexpert](https://www.lexpert.ca/news/technology-law/ai-laws-update-what-now-after-artificial-intelligence-and-data-act/394712) T2 · Retrieved · retrieved 2 Nov 2026Manitoba's Public Sector Artificial Intelligence and Cybersecurity Governance Act received Royal Assent in June 2026. - The federal Directive on Automated Decision-Making applies to production automated decision systems used by federal institutions for administrative decisions, excluding research and test systems.Confidence: Probable · EvidencedEvidence and sources[Treasury Board of Canada Secretariat](https://www.canada.ca/en/government/system/digital-government/digital-government-innovations/responsible-use-ai/automated-decision-making/guide-scope-directive-automated-decision-making.html) T1 · Retrieved · retrieved 27 Jun 2024The automated decision systems could use rules, regression, advanced analytics, AI, generative AI, machine learning, neural networks - [Treasury Board of Canada Secretariat](https://search.open.canada.ca/qpnotes/record/tbs-sct%2CTBS-2025-QP-06-00031) T1 · Retrieved · retrieved 19 Jun 2025The Directive sets out rules for how departments and agencies can use automated systems in service decisions. - Existing federal automated decision systems have until 24 June 2026 to comply with the Directive's updated requirements.Confidence: Probable · As of 24 Jun 2025 · EvidencedEvidence and sources[Treasury Board of Canada Secretariat](https://www.tbs-sct.canada.ca/pol/doc-eng.aspx?id=32592) T1 · Retrieved · retrieved 4 Nov 2026Existing automated decision systems developed or procured prior to June 24, 2025, will have until June 24, 2026 - OSFI's Guideline E-23 on model risk management, covering AI/ML models at federally regulated financial institutions, takes effect on 1 May 2027.Confidence: Confirmed · As of 11 Sep 2025 · EvidencedEvidence and sources[Office of the Superintendent of Financial Institutions (OSFI)](https://www.osfi-bsif.gc.ca/en/news/backgrounder-guideline-e-23-model-risk-management) T1 · Retrieved · retrieved 11 Nov 2026sets out OSFI's expectations for how federally regulated financial institutions should manage risks associated with the use of models. - [McMillan LLP](https://mcmillan.ca/insights/publications/model-risk-governance-for-financial-institutions-new-guidance-for-a-new-era/) T3 · SurfacedOn September 11, 2025, the Office of the Superintendent of Financial Institutions ("OSFI") released Guideline E-23 - [Blakes](https://www.blakes.com/insights/osfi-releases-final-guideline-e-23-for-model-risk-management-and-ai-use-by-frfis/) T3 · Retrieved · retrieved 11 Nov 2026The Final Guideline, which will take effect on May 1, 2027, addresses emerging technology risks and imposes - Manitoba's Public Sector AI and Cybersecurity Governance Act received Royal Assent on 1 June 2026 but is not yet in force.Confidence: Confirmed · As of 1 Jun 2026 · EvidencedEvidence and sources[Government of Manitoba / Queen's Printer](https://web2.gov.mb.ca/laws/statutes/2026/c04326.php?lang=en) T1 · Retrieved · retrieved 1 Jun 2026This Act applies to prescribed public sector entities. - [Fillmore Riley LLP](https://www.fillmoreriley.com/publication/manitoba's-new-ai-and-cybersecurity-governance-framework-for-the-public-sector) T3 · Retrieved · retrieved 4 Nov 2026The Act received Royal Assent on June 1, 2026, but is not yet in force. - [Lexpert](https://www.lexpert.ca/news/technology-law/ai-laws-update-what-now-after-artificial-intelligence-and-data-act/394712) T2 · Retrieved · retrieved 2 Nov 2026Manitoba's Public Sector Artificial Intelligence and Cybersecurity Governance Act received Royal Assent in June 2026. - Ontario's EDSTA has been in force since 29 January 2025, but its AI-specific duties remain inoperative because no prescribing regulation has been made.Confidence: Probable (capped: best source is T3) · As of 29 Jan 2025 · EvidencedEvidence and sources[fruggr.io](https://www.fruggr.io/en/ontario-bill-194-ai-public-sector-rules-2026/) T3 · RetrievedBill 194's AI duties (disclosure, accountability framework, risk management, human oversight) are a frame; they bind only when - [McCarthy Tétrault LLP](https://www.mccarthy.ca/en/insights/blogs/techlex/ontario-bill-194-strengthening-cyber-security-and-building-trust-in-the-public-sector) T3 · Surfacedthe EDST creates requirements to comply but rules out the establishment of a private law duty of care - [WeirFoulds LLP](https://www.weirfoulds.com/bill-194-how-public-sector-institutions-should-prepare-for-it) T3 · Retrieved · retrieved 4 Nov 2026Bill 194, which introduces cybersecurity and artificial intelligence (AI) requirements in Ontario's public sector, received Royal Assent - [regulations.ai](https://regulations.ai/regulations/RAI-CA-NA-SCSBTXX-2024) T4 · Retrieved · retrieved 4 Nov 2026The core rules under the Enhancing Digital Security and Trust Act took effect on January 29, 2025 - Federal institutions must complete an Algorithmic Impact Assessment before putting an automated decision system into production, under the Directive on Automated Decision-Making.Confidence: Uncertain (Capped from Probable: best source is T4) · As of 1 Apr 2019 · EvidencedEvidence and sources[regulations.ai](https://regulations.ai/regulations/canada-2019-3-directive-automated-decision-making) T4 · Retrieved · retrieved 4 Nov 2026mandates Algorithmic Impact Assessments and human oversight for federal institutions using automated decision systems - Manitoba's Public Sector Artificial Intelligence and Cybersecurity Governance Act received Royal Assent on 1 June 2026 but is not yet in force pending proclamation and regulations.Confidence: Probable (capped: best source is T3) · As of 1 Jun 2026 · EvidencedEvidence and sources[Torys LLP](https://www.torys.com/our-latest-thinking/publications/2026/06/manitoba-introduces-algorithmic-pricing-and-public-sector-ai-regulation) T3 · Retrieved · retrieved 4 Nov 2026Entities subject to the Act will be required to be transparent about their use of such systems - Manitoba prohibited personalized algorithmic pricing toward Manitoba consumers without consent under an amendment to the Business Practices Act, Royal Assent 1 June 2026.Confidence: Uncertain (Capped from Probable: best source is T4) · As of 1 Jun 2026 · EvidencedEvidence and sources[Mondaq](https://www.mondaq.com/canada/new-technology/1801730/manitoba-introduces-algorithmic-pricing-and-public-sector-ai-regulation) T4 · Surfaced · retrieved 4 Nov 2026Manitoba has prohibited the use of personalized algorithmic pricing for Manitoba consumers without their consent - Ontario's Enhancing Digital Security and Trust Act took effect 29 January 2025, but its AI-specific obligations remain inoperative pending regulations prescribing covered uses.Confidence: Probable · As of 29 Jan 2025 · EvidencedEvidence and sources[Legislative Assembly of Ontario](https://www.ola.org/en/legislative-business/bills/parliament-43/session-1/bill-194) T1 · Retrieved · retrieved 4 Nov 2026The Lieutenant Governor in Council may make regulations governing the use of artificial intelligence systems by public sector entities - OSFI's final Guideline E-23 on model risk management, published 11 September 2025, takes effect 1 May 2027 and explicitly covers AI/ML models at federally regulated financial institutions.Confidence: Probable (capped: best source is T3) · As of 11 Sep 2025 · EvidencedEvidence and sources[McMillan LLP](https://mcmillan.ca/insights/publications/model-risk-governance-for-financial-institutions-new-guidance-for-a-new-era/) T3 · SurfacedOn September 11, 2025, the Office of the Superintendent of Financial Institutions ("OSFI") released Guideline E-23 - The Government of Canada published a minimum-viable-product AI transparency register disclosing federal AI systems on 28 November 2025.Confidence: Probable · As of 28 Nov 2025 · EvidencedEvidence and sources[Government of Canada / Treasury Board of Canada Secretariat](https://open.canada.ca/data/en/dataset/fcbc0200-79ba-4fa4-94a6-00e32facea6b) T1 · Retrieved · retrieved 4 Nov 2026The Government of Canada (GC) Artificial Intelligence (AI) Register collects information about the Government of Canada's AI systems. - OSFI's final Guideline E-23 extends model risk management expectations to AI/ML models used by federally regulated financial institutions, taking effect 1 May 2027.Confidence: Confirmed · As of 11 Sep 2025 · EvidencedEvidence and sources[Office of the Superintendent of Financial Institutions (OSFI)](https://www.osfi-bsif.gc.ca/en/news/backgrounder-guideline-e-23-model-risk-management) T1 · Retrieved · retrieved 11 Nov 2026sets out OSFI's expectations for how federally regulated financial institutions should manage risks associated with the use of models. - The Government of Canada published a Minimum Viable Product AI Register in November 2025 and a What We Heard Report on it in September 2026.Confidence: Probable · As of 11 Sep 2026 · EvidencedEvidence and sources[Government of Canada / Treasury Board of Canada Secretariat](https://www.canada.ca/en/government/system/digital-government/digital-government-innovations/responsible-use-ai/advancing-ai/progress.html) T1 · Retrieved · retrieved 11 Nov 2026The Algorithmic Impact Assessment tool was updated to support changes to the directive. ### 08Safety & Incident ReportingActive▾# Directive on Automated Decision-Making (In force since 2019-04-01). 1 instrument (1 current) · 0 obligations · 2 claims · 0 milestones The Treasury Board Secretariat's Directive on Automated Decision-Making requires federal institutions to publish information on the effectiveness and efficiency of an automated decision system in meeting program objectives, on the Open Government Portal, on a periodic basis following deployment. The Government of Canada published a minimum-viable-product AI transparency register disclosing federal AI systems on 28 November 2025. Instruments (1) - Directive on Automated Decision-Making In force since 2019-04-01Regulatory expectation Claims and evidence (2) - The Directive on Automated Decision-Making requires federal institutions to publish information on the effectiveness and efficiency of an automated decision system in meeting program objectives, on the Open Government Portal, on a periodic basis post-deployment.Confidence: Probable · EvidencedEvidence and sources[Government of Canada / Treasury Board of Canada Secretariat](https://www.canada.ca/en/government/system/digital-government/digital-government-innovations/responsible-use-ai/advancing-ai/progress.html) T1 · Retrieved · retrieved 11 Nov 2026The Algorithmic Impact Assessment tool was updated to support changes to the directive. - The Government of Canada published a minimum-viable-product AI transparency register disclosing federal AI systems on 28 November 2025.Confidence: Probable · As of 28 Nov 2025 · EvidencedEvidence and sources[Government of Canada / Treasury Board of Canada Secretariat](https://open.canada.ca/data/en/dataset/fcbc0200-79ba-4fa4-94a6-00e32facea6b) T1 · Retrieved · retrieved 4 Nov 2026The Government of Canada (GC) Artificial Intelligence (AI) Register collects information about the Government of Canada's AI systems. ### 09Standards & ConformityActive Derived: Probable▾# Canada's proposed Artificial Intelligence and Data Act (AIDA) died on the Order Paper when Parliament was prorogued on 6 January 2025, and no successor AI statute has been introduced, so Canada has no horizontal AI statute in force. 1 instrument (0 current) · 0 obligations · 2 claims · 0 milestones Canada has no horizontal AI conformity-assessment or standards regime in force. The Artificial Intelligence and Data Act (Part 3 of Bill C-27), which would have established Canada's first standards and conformity framework for high-impact AI systems, died on the Order Paper when Parliament was prorogued on 6 January 2025, and no successor AI statute has been introduced, leaving Canada without a horizontal AI statute establishing such requirements as of the run date. Instruments (1) - Artificial Intelligence and Data Act (AIDA), Part 3 of Bill C-27 Ended 2025-01-06 Not currentDraft, no legal force Claims and evidence (2) - Derived: Probable Canada's proposed Artificial Intelligence and Data Act (AIDA) died on the Order Paper when Parliament was prorogued on 6 January 2025, and no successor AI statute has been introduced, so Canada has no horizontal AI statute in force.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[sanitized.ai](https://sanitized.ai/standards/aida-bill-c-27/) T3 · Retrieved · retrieved 4 Nov 2026Canada's proposed AI law died when Parliament was prorogued in January 2025, and no successor AI act has been - Derived: Probable AIDA (Bill C-27 Part 3) died on the Order Paper when Parliament was prorogued on 6 January 2025, and no successor AI act has been introduced.Confidence: Probable (capped: best source is T3) · As of 6 Jan 2025 · EvidencedEvidence and sources[sanitized.ai](https://sanitized.ai/standards/aida-bill-c-27/) T3 · Retrieved · retrieved 4 Nov 2026Canada's proposed AI law died when Parliament was prorogued in January 2025, and no successor AI act has been ### 10Authorities & EnforcementActive Derived: Probable▾# Act respecting the protection of personal information in the private sector (Quebec) (In force since 2023-09-22). 1 instrument (1 current) · 0 obligations · 5 claims · 0 milestones Under Quebec's Law 25, a person designated by the Commission d'accès à l'information has the power to impose administrative monetary penalties of up to C$10 million or 2% of worldwide turnover, whichever is greater, for breach of the automated-decision disclosure duty, with a separate penal-offence track reaching up to C$25 million or 4% of worldwide turnover. In a joint investigation reported as PIPEDA Findings #2026-002, the federal Privacy Commissioner, together with Quebec's Commission d'accès à l'information and the British Columbia and Alberta privacy commissioners, found that an AI provider's usage policies do not affirmatively prohibit using its outputs to support high-stakes decisions in employment, financial or government-service contexts; the broader applicability of this finding beyond the investigated provider remains under consideration. Instruments (1) - Act respecting the protection of personal information in the private sector (Quebec) In force since 2023-09-22Binding Claims and evidence (5) - Derived: Probable Quebec's Law 25 empowers a CAI-designated person to impose administrative monetary penalties of up to C$10 million or 2% of worldwide turnover (whichever is greater) for breach of the automated-decision disclosure duty, with a separate penal-offence track reaching C$25 million or 4% of worldwide turnover.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[Osler, Hoskin & Harcourt LLP](https://www.osler.com/en/insights/updates/law-25-a-new-enforcement-scheme-for-protection-of-personal-information-in-the-private-sector-in-que/) T3 · RetrievedLaw 25 provides for administrative monetary penalties (AMPs) of up to C$10 million or the amount corresponding to 2% - [Borden Ladner Gervais LLP](https://www.blg.com/-/media/insights/documents/blg-quebec-bill-64-october-guide3.pdf) T3 · Retrieveda "person designated by the Commission, but who is not a member of any of its divisions" will have - Derived: Probable A joint investigation by Canada's federal Privacy Commissioner with Quebec's CAI and the British Columbia and Alberta commissioners (PIPEDA Findings #2026-002) found that OpenAI's usage policies do not permit automating high-stakes decisions in employment, financial or essential government-service contexts without human review, but do not affirmatively prohibit using its outputs to support decision-making in those areas.Confidence: Confirmed · EvidencedEvidence and sources[Office of the Privacy Commissioner of Canada](https://www.priv.gc.ca/en/opc-actions-and-decisions/investigations/investigations-into-businesses/2026/pipeda-2026-002/) T1 · Retrieved · retrieved 4 Nov 2026OpenAI's policies do not permit the automation of high-stakes decisions in sensitive areas (such as employment, financial activities - A CAI-designated person has power to impose administrative monetary penalties for breach of Quebec's automated-decision disclosure duty.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[Borden Ladner Gervais LLP](https://www.blg.com/-/media/insights/documents/blg-quebec-bill-64-october-guide3.pdf) T3 · Retrieveda "person designated by the Commission, but who is not a member of any of its divisions" will have - [Osler, Hoskin & Harcourt LLP](https://www.osler.com/en/insights/updates/law-25-a-new-enforcement-scheme-for-protection-of-personal-information-in-the-private-sector-in-que/) T3 · RetrievedLaw 25 provides for administrative monetary penalties (AMPs) of up to C$10 million or the amount corresponding to 2% - Breach of Quebec's automated-decision disclosure duty can draw an administrative penalty up to CAD $10 million / 2% of turnover, or a penal fine up to CAD $25 million / 4% of turnover.Confidence: Probable (capped: best source is T3) · EvidencedEvidence and sources[Osler, Hoskin & Harcourt LLP](https://www.osler.com/en/insights/updates/law-25-a-new-enforcement-scheme-for-protection-of-personal-information-in-the-private-sector-in-que/) T3 · RetrievedLaw 25 provides for administrative monetary penalties (AMPs) of up to C$10 million or the amount corresponding to 2% - Derived: Probable The federal Privacy Commissioner, with Quebec's CAI and the BC and Alberta commissioners, found in a joint investigation that an AI provider's usage policies do not affirmatively prohibit using its outputs to support high-stakes decisions in employment, financial or government-service contexts.Confidence: Probable · EvidencedEvidence and sources[Office of the Privacy Commissioner of Canada](https://www.priv.gc.ca/en/opc-actions-and-decisions/investigations/investigations-into-businesses/2026/pipeda-2026-002/) T1 · Retrieved · retrieved 4 Nov 2026OpenAI's policies do not permit the automation of high-stakes decisions in sensitive areas (such as employment, financial activities ### 11Sandboxes & Transitional ReliefActive Derived: Probable▾# Public Sector Artificial Intelligence and Cybersecurity Governance Act (Manitoba) (Draft, no legal force). 1 instrument (1 current) · 0 obligations · 4 claims · 0 milestones No regulatory sandbox or testing-cohort programme for AI systems has been recorded for Canada. Existing transitional relief arises instead from statutory and policy compliance deadlines: federal automated decision systems developed or procured before 24 June 2025 have until 24 June 2026 to comply with the updated requirements of the Treasury Board Secretariat's Directive on Automated Decision-Making. The Office of the Superintendent of Financial Institutions' Guideline E-23 on Model Risk Management, published 11 September 2025, extends model-risk governance expectations to AI and machine-learning models used by federally regulated financial institutions, with its effective date set at 1 May 2027. Manitoba's Public Sector Artificial Intelligence and Cybersecurity Governance Act received Royal Assent on 1 June 2026 but remains pending proclamation and implementing regulations before it takes effect. Instruments (1) - Public Sector Artificial Intelligence and Cybersecurity Governance Act (Manitoba) Draft, no legal force Claims and evidence (4) - Derived: Probable Existing federal automated decision systems developed or procured prior to 24 June 2025 have until 24 June 2026 to comply with the updated requirements of the Directive on Automated Decision-Making.Confidence: Probable · EvidencedEvidence and sources[Treasury Board of Canada Secretariat](https://www.tbs-sct.canada.ca/pol/doc-eng.aspx?id=32592) T1 · Retrieved · retrieved 4 Nov 2026Existing automated decision systems developed or procured prior to June 24, 2025, will have until June 24, 2026 - Derived: Probable OSFI's Guideline E-23 on Model Risk Management, published 11 September 2025, extends model-risk governance expectations explicitly to AI/ML models used by federally regulated financial institutions and takes effect 1 May 2027.Confidence: Confirmed · EvidencedEvidence and sources[Office of the Superintendent of Financial Institutions (OSFI)](https://www.osfi-bsif.gc.ca/en/news/backgrounder-guideline-e-23-model-risk-management) T1 · Retrieved · retrieved 11 Nov 2026sets out OSFI's expectations for how federally regulated financial institutions should manage risks associated with the use of models. - [McMillan LLP](https://mcmillan.ca/insights/publications/model-risk-governance-for-financial-institutions-new-guidance-for-a-new-era/) T3 · SurfacedOn September 11, 2025, the Office of the Superintendent of Financial Institutions ("OSFI") released Guideline E-23 - [Blakes](https://www.blakes.com/insights/osfi-releases-final-guideline-e-23-for-model-risk-management-and-ai-use-by-frfis/) T3 · Retrieved · retrieved 11 Nov 2026The Final Guideline, which will take effect on May 1, 2027, addresses emerging technology risks and imposes - Derived: Probable Manitoba's Public Sector Artificial Intelligence and Cybersecurity Governance Act received Royal Assent on 1 June 2026 but was not yet in force as of the run date, pending proclamation and implementing regulations.Confidence: Probable · EvidencedEvidence and sources[Fillmore Riley LLP](https://www.fillmoreriley.com/publication/manitoba's-new-ai-and-cybersecurity-governance-framework-for-the-public-sector) T3 · Retrieved · retrieved 4 Nov 2026The Act received Royal Assent on June 1, 2026, but is not yet in force. - [Government of Manitoba / Queen's Printer](https://web2.gov.mb.ca/laws/statutes/2026/c04326.php?lang=en) T1 · Retrieved · retrieved 1 Jun 2026This Act applies to prescribed public sector entities. - Manitoba's Public Sector Artificial Intelligence and Cybersecurity Governance Act received Royal Assent on 1 June 2026 but is not yet in force pending proclamation and regulations.Confidence: Probable (capped: best source is T3) · As of 1 Jun 2026 · EvidencedEvidence and sources[Torys LLP](https://www.torys.com/our-latest-thinking/publications/2026/06/manitoba-introduces-algorithmic-pricing-and-public-sector-ai-regulation) T3 · Retrieved · retrieved 4 Nov 2026Entities subject to the Act will be required to be transparent about their use of such systems ### 12Commercial ActivityQuiet▾# Nothing recorded for this module in the research of 2026-11-12. 0 instruments · 0 obligations · 0 claims Nothing recorded for this module in the research of 2026-11-12. No modules match. Filters combine as OR inside a group and AND across groups. Reset all filters ## Authorities No authorities recorded in this research. ## Enforcement actions No enforcement actions recorded in this research. ## Cases No cases recorded in this research. ## Consultations No consultations recorded in this research. What this record does not yet establish is set out on the [transparency register](/gaps/#gap-ca); its dated events are on the [regulatory calendar](/calendar/?jid=CA). Think something on this page is wrong? [Report an error](/legal/#contact). Technical provenance (record schema, run ID & build metadata) Schema version artificial-intelligence-record-v2.12 Research run ID aic-union-CA-2026-11-04 Page model module-card-page-v1 Renderer render_jid_aic_v13 Build date 12 Nov 2026