AI Governance in Canada: Why Professional Regulators Must Lead in the Absence of Federal Legislation
The Canadian AI Regulatory Landscape
Canada currently operates without comprehensive federal legislation governing artificial intelligence (AI); the national AI rulebook is still a work in progress. The federal bill that would have created a national AI law, Bill C-27—which included the Artificial Intelligence and Data Act (AIDA)—lapsed at prorogation in January 2025. Since then, no successor bill has cleared first reading, and timelines remain uncertain. However, the absence of a single “AI statute” does not give regulatory Boards and Councils a governance pass; you still have duties defined by existing privacy laws, administrative fairness expectations, and your statutory mandate to protect the public interest, against a shifting set of international norms, such as the OECD principles (the first intergovernmental standard on AI).
The absence of a single “AI statute” does not give regulatory Boards and Councils a governance pass; you still have duties defined by existing privacy laws, administrative fairness expectations, and your statutory mandate to protect the public interest.
In practice, Canadian regulatory bodies already operate under enforceable requirements, such as provincial and territorial public-sector/health privacy laws, whenever AI involves personal information or decisions affecting people.
In the absence of federal legislation, Ottawa has turned to voluntary frameworks to guide AI governance. With Bill C-27/AIDA off the table for now, Ottawa is steering practice through soft-law tools, most notably the Voluntary Code of Conduct for Advanced Generative AI (Voluntary Code). The Voluntary Code distills “responsible AI” into six principles: accountability, safety, transparency, fairness and equity, human oversight and monitoring, and ensuring these systems are credible and robust.
Canada’s Voluntary Code of Conduct for Advanced Generative AI distills “responsible AI into six principles: accountability, safety, transparency, fairness and equity, human oversight and monitoring, and ensuring these systems are credible and robust.
It also includes…
Leading with a security-first mentality
As technology rapidly develops, the number of security and privacy concerns will only continue …
