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Security & Compliance6 min read

Ottawa Is Drafting AI Transparency Rules. Speak Now.

August 20, 2026By Ajan Kanagalingam

Innovation, Science and Economic Development Canada has a public consultation on AI transparency open until 23 September, part of the AI for All strategy launched in June. It asks how Canada should handle five specific things, and unlike most government consultations, all five land directly on how ordinary businesses already use AI. Almost nobody outside large firms and industry associations will respond, which is exactly why a thirty-minute reply from a small Canadian business is worth more than it sounds.

The five questions on the table

AreaWho it lands on
Detecting AI-generated contentContent producers and platforms
Telling people they are talking to AIAnyone with a chat or voice assistant
Making AI system details accessibleMostly vendors and large deployers
Tracking serious AI incidentsPotentially anyone deploying AI
Monitoring AI agent activityAnyone running agents in production

Rows two and five are the ones to read carefully if you run a small business. Disclosing AI interaction touches every company with a website chat assistant, an AI phone answering service, or automated email replies, which by now is an enormous number of perfectly ordinary firms. Agent monitoring matters because agents are moving from experiment into production faster than governance is following, and any recordkeeping duty lands on whoever deployed them rather than whoever built them.

Why your response counts more than you think

Consultation responses come overwhelmingly from large companies, industry associations, and advocacy organisations, all of whom employ someone whose job includes writing them. The lived reality of a twenty-person firm in Kitchener or Moncton rarely reaches the file at all. That is how rules end up technically sensible and practically awkward for smaller operators, not through malice but through absence. Describing what you actually do, and which proposed obligation would be genuinely hard for a business your size, is information nobody else in the process is providing.

Nothing is mandatory, and that is the point

This is a consultation about what rules should look like, not a rule. Your existing obligations are unchanged: PIPEDA federally, Quebec's Law 25 if you handle personal information there, and whatever governs your sector. We set out the current landscape in what actually regulates AI in Canada in 2026. The reason to engage now is timing. Once a framework is drafted the direction is largely settled and everyone is arguing about details. The consultation stage is the only point where the shape itself is genuinely open.

The work that is useful either way

Whatever emerges, every plausible version starts from the same place: knowing where AI touches your business. Write the list. What each use does, who owns it, and whether customers are told. That inventory is not speculative compliance work, because you need it for ordinary management too, and most small businesses do not have it, which is the gap behind using AI without managing it. An afternoon now beats a scramble later, and it produces a better list than one written against a deadline.

Disclosure is the one to get ahead of

Of the five areas, telling customers when they are dealing with AI is the one most likely to become a firm expectation, because it is the easiest to write, the easiest to check, and the one the public most clearly wants. It is also the cheapest to adopt voluntarily, and businesses that do it early tend to find customers respond well rather than badly, which is the argument in when to disclose AI to customers. Doing it before you are required to converts a future compliance task into a present trust advantage. That is a rare trade and it is available now.

Thirty minutes, before 23 September

ISED accepts responses through an online survey or by email, and you do not need legal drafting or a policy position. Plain description works: here is what we use AI for, here is how we tell customers, here is what would be difficult and why. The wider strategy this sits inside is covered in Canada's AI for All strategy. Check the ISED page for the current deadline and submission route before you write, then take half an hour. Rules get written either way; the only question is whether anyone in them sounds like you.

Frequently Asked Questions

What is the consultation?

Innovation, Science and Economic Development Canada opened a public consultation on AI transparency in late July, running through 23 September 2026, as part of the AI for All national strategy. It asks how Canada should approach five things: detecting AI-generated content, telling people when they are interacting with an AI system, making details about AI systems more accessible, tracking serious AI incidents, and monitoring AI agent activity. Confirm the current deadline and submission route on the ISED site before relying on either, since consultation timelines do occasionally move.

Why should a small business bother responding?

Because the people who respond to consultations are overwhelmingly large companies, industry associations, and advocacy groups, all of whom have a full-time person for this. The operational reality of a twenty-person firm rarely reaches the file, which is how rules end up technically reasonable and practically awkward for smaller operators. A short response describing what you actually do and what would be genuinely hard costs perhaps thirty minutes. It is the cheapest influence available on rules you will be living with for years.

Which of the five areas matters most to us?

For most small businesses, the second and fifth. Telling people when they are interacting with an AI system touches anyone running a chat assistant, an AI phone answering service, or automated replies, which is now a very large number of ordinary companies. Monitoring AI agent activity matters because agents are moving from experiment to production quickly and any recordkeeping requirement lands on whoever deployed them. The other three matter more to content producers, vendors, and larger deployers, though the incident-tracking question could reach anyone.

Is anything mandatory right now?

No. This is a consultation about what future rules should look like, not a rule. Existing obligations still apply: PIPEDA federally, Quebec’s Law 25 for businesses handling personal information in that province, plus whatever sector rules govern your industry. The reason to act now is timing rather than compliance. Once a framework is drafted, the arguments are largely over and you are responding to specifics rather than shaping direction. Consultation stage is where the shape gets decided.

What should we do besides responding?

Write down where AI touches your business, what each use does, and how customers are told about it, if they are. Nearly every plausible version of these rules starts with knowing your own AI inventory, so the work is not speculative. It also happens to be the same list you need for ordinary management, since you cannot govern uses nobody has ever recorded. Doing it now takes an afternoon. Doing it in response to a deadline takes considerably longer and produces a worse list.

Get ahead of Canadian AI transparency rules

We help Canadian businesses inventory their AI use, set up customer disclosure that builds trust, and stay ready for what Ottawa drafts next.

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AK
Ajan Kanagalingam
Founder & ChatGPT Consultant, ChatGPT.ca

Ajan leads the ChatGPT.ca team: 200+ custom GPT builds and automation projects for 50+ businesses across 20+ industries. Based in Markham, Ontario. PIPEDA-compliant solutions.

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