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22.10.2026Priority 3: MediumQuebecCanada

Quebec's CAI warns that dark patterns can invalidate consent

What changed

The Commission d'accès à l'information published new guidance on dark patterns, meaning interface designs that steer users toward decisions against their own interest. Examples include disclosing more personal information, spending more time on a platform or spending more money. The CAI states that consent obtained through such an interface may be invalid, which would make the resulting use or communication of personal information unlawful. The guidance sets out the applicable legal obligations and best practices for organizations that collect personal information from Quebec users online.

Source: View the official source

Why it matters

  • Consent collected through a manipulative interface may be invalid under Quebec privacy law.
  • Any use or communication of personal information that relies on that consent may then be unlawful.
  • Product, design and marketing teams that serve Quebec users are directly concerned.

Our comment

The guidance places interface design within the scope of consent validity under Quebec privacy law. The legal question is no longer only whether consent was requested, but whether the way it was requested left the user a real choice. For product and marketing teams, design decisions now carry a compliance dimension that the CAI has said it will assess.

Sara Derbel

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Sara Derbel

Paralegal

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