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23.10.2026Priority 4: LowCanada

Privacy Commissioner of Canada comments on AI transparency consultation

What changed

The Office of the Privacy Commissioner of Canada released its comments on Innovation, Science and Economic Development Canada's consultation on AI transparency, which ran from July 23 to September 23, 2026. The OPC agrees that transparency issues arise in all five areas ISED identified: AI generated content, AI interaction, information about AI systems, AI incidents and AI agents. It argues that information about a system must be understandable at the point where it affects an individual's decision. The OPC anchors its position in its existing consent guidelines and names developers and deployers of generative AI as bearing transparency responsibilities.

Source: View the official source

Why it matters

The OPC reads AI transparency through its existing meaningful consent guidelines under PIPEDA.
Information about an AI system should be understandable at the moment it affects a person's decision.
Both developers and organizations that deploy generative AI are named as responsible for transparency.

Our comment

By grounding its comments in existing consent guidance, the OPC signals that current PIPEDA principles already frame its expectations for AI transparency. The question for organizations deploying AI in Canada is how their present disclosures would be read against that standard, independently of any future AI legislation.

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Sara Derbel

Paralegal

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