Canada's privacy commissioner publishes comments on an AI transparency paper

The Office of the Privacy Commissioner of Canada said on 23 October 2026 that it has published its submission to Innovation, Science and Economic Development Canada on the discussion paper Enhancing trust in artificial intelligence through increased transparency. The letter itself is dated 23 September 2026. The OPC's submissions index also dates the publication 23 October 2026.

The news release says the OPC concurs that transparency issues can arise in five areas named by ISED: AI-generated content, AI interaction, information about AI systems, AI incidents, and AI agents. The submission says information about AI systems must be understandable and accessible at the time it is relevant to a person's decision, not only available. It points to PIPEDA's rules that purposes must be stated so the individual can reasonably understand them, and that consent is valid only where the individual would understand the nature, purpose and consequences of the processing.

On AI interaction, the submission says two situations particularly matter: when an organisation uses an automated decision system to make or inform a significant prediction, recommendation or decision about a person, and when personal information is collected or used by an AI system, including where the person does not deal with the system directly. It says there can be a risk of over-disclosure. It is advice to a government consultation. It is not a new law, and it does not change the status of Bill C-36.

What it means for business: no new Canadian AI rule takes effect from this publication. Organisations that use AI with personal information in Canada can read it as the privacy regulator's view that a transparency notice should be understandable at the moment someone decides, and that it should sit with existing privacy notices rather than as a separate pile of documents.