No Canadian law requires it. But if the ad's claims are false or misleading, the Competition Act applies exactly the same as it always has, label or no label.
Short answer
No Canadian law requires it. There's guidance pointing that way — a voluntary federal code and Canada's privacy commissioners both say AI-made content should be identified in some circumstances — but nothing binding forces a label onto an ad, and if the ad's claims are false or misleading, the Competition Act applies exactly the same as it always has, label or no label.
Canada has no AI-content-labelling statute. The federal government's own Voluntary Code of Conduct asks its signed-up organizations — a defined, closed list, not every business — to ensure that “systems that could be mistaken for humans are clearly and prominently identified as AI systems.” But the code adds, plainly, that “this code does not in any way change existing legal obligations that organizations may have.” (ISED, Voluntary Code of Conduct on Advanced Generative AI Systems) If your business hasn't signed it, it isn't binding on you.
Canada's federal, provincial and territorial privacy commissioners jointly ask that “system outputs that could have a significant impact on an individual or group are meaningfully identified as being created by a generative AI tool.” (OPC, Principles for generative AI) That's guidance interpreting existing privacy law, not an advertising-labelling rule, and its own “significant impact” test is narrower than “every ad.”
The Competition Act's misleading-representation rules don't care whether AI wrote the ad; a false or misleading claim is caught either way, and the onus sits on the business making it — see how the reversed-onus performance-claim rule applies to AI-drafted copy. The Competition Bureau has already flagged where AI raises the stakes on this: it can be used to make deceptive marketing conduct “more convincing, using ‘deepfake’ (digitally altered) voices, images, or videos,” which is a real, live concern — and a separate one from whether an ordinary AI-drafted ad carries a label. (Competition Bureau, Artificial intelligence and competition) The same reasoning covers a chatbot's spoken claims, not just published copy — see whether a chatbot's answer can bind your business.
See how disclosure and compliance get built into a customer-facing AI campaign from the start.
