Canadian privacy and AI horizon shifts again

Canada’s latest parliamentary session ended abruptly when Parliament was prorogued on January 6, 2025. As a result, all bills in progress have died on the order paper – including Bill C-27 (introduced in late 2021), which would replace Canada’s federal private-sector privacy legislation, the Personal Information Protection and Electronic Documents Act (PIPEDA) with a new Consumer Privacy Protection Act and create the new Artificial Intelligence and Data Act (AIDA).

This means that Canada’s federal privacy regime will remain as-is for the foreseeable future, without the modernizations and improvements to PIPEDA that many were anticipating in 2025. This is not the first time federal privacy reform has been delayed, as a predecessor PIPEDA reform bill that was introduced in 2020 similarly died in 2021 due to a federal election.

AIDA was the first Canadian attempt at broad-based regulation of artificial intelligence systems. AIDA, as drafted, was light on necessary details, which were to be included in regulations that were never published (though the government did release a companion paper in 2023 outlining some of its plans). The government indicated it did not expect AIDA to come into force any sooner than 2025 and it is now uncertain when, and in what form, there will be federal AI-focused regulation in Canada.

Parliament is prorogued until March 24, 2025, and is unclear what legislative agenda will be implemented when Parliament resumes. Should Bill C-27 be picked up where it left off, it is not obvious that any new laws will be passed before the next federal election, which must take place by late October 2025 at the latest (and is likely to happen in late Spring 2025).

For now, all that’s clear is that Canada’s federal privacy reform has been postponed again, and that Canada will be without specific and broad-based federal AI regulation for the foreseeable future.