Treadstone Associates
Article · 9 min read

What AIDA proposed and where it stands

A great deal is said about the Artificial Intelligence and Data Act without anyone reading what it actually says. The bill’s own text, and Parliament’s own tracking page for it, both answer the question more precisely than the shorthand version most people repeat.

Treadstone Associates · Updated 2026

Key takeaways

  • • AIDA was Part 3 of Bill C-27, introduced at first reading on June 16, 2022, alongside two new privacy statutes.
  • • It would have regulated “high-impact” AI systems — but the bill itself left the definition of which systems count as high-impact entirely to future regulations, not fixed in the bill’s own text.
  • • Its enforcement figure, the Artificial Intelligence and Data Commissioner, would not have been an independent regulator — the bill defines the role as a senior official inside the Minister’s own department, assisting the Minister rather than acting independently of them.
  • • As recorded on LEGISinfo, read 27 August 2026, the bill’s status is “At consideration in committee in the House of Commons,” against a session the page itself marks as prior. Nothing past that sentence should be asserted about where it stands.

Two separate things get blurred together when people talk about AIDA: what the bill would have actually required, and what has happened to it procedurally since it was introduced. Both deserve a straight answer, read from the source rather than from the shorthand version that circulates.

What it was part of

AIDA was never a standalone bill. It was Part 3 of Bill C-27, introduced at first reading on June 16, 2022, under the short title Digital Charter Implementation Act, 2022. The bill’s own summary describes Part 3 as enacting “the Artificial Intelligence and Data Act to regulate international and interprovincial trade and commerce in artificial intelligence systems by requiring that certain persons adopt measures to mitigate risks of harm and biased output related to high-impact artificial intelligence systems,” and states that the Act “also establishes prohibitions related to the possession or use of illegally obtained personal information for the purpose of designing, developing, using or making available for use an artificial intelligence system” (Bill C-27, first reading, Summary). Parts 1 and 2 of the same bill would have enacted the Consumer Privacy Protection Act and the Personal Information and Data Protection Tribunal Act — AIDA was one-third of a larger digital-charter package, not a bill on its own.

How the bill defined its own key terms

Reading the bill’s own definitions section clears up more than any summary can. It defines an “artificial intelligence system” as “a technological system that, autonomously or partly autonomously, processes data related to human activities through the use of a genetic algorithm, a neural network, machine learning or another technique in order to generate content or make decisions, recommendations or predictions” (Bill C-27, cl.5(1)). “Biased output” is defined as content, or a decision, recommendation or prediction, that “adversely differentiates, directly or indirectly and without justification, in relation to an individual on one or more of the prohibited grounds of discrimination set out in section 3 of the Canadian Human Rights Act,” with an explicit carve-out for content whose purpose and effect is to reduce disadvantages those grounds already cause. “Harm” is defined narrowly and concretely: “(a) physical or psychological harm to an individual; (b) damage to an individual’s property; or (c) economic loss to an individual.” None of these three definitions is vague filler — each one does real work determining what the rest of the Act would have applied to.

The gap at the centre: “high-impact” was never defined in the bill

This is the detail most summaries skip, and it is the single most consequential one. The bill’s own definitions clause states: “high-impact system means an artificial intelligence system that meets the criteria for a high-impact system that are established in regulations” (Bill C-27, cl.5(1)). Read that again: the entire regulatory scheme turns on a category the bill itself does not define. Whether a given AI system would have counted as “high-impact,” and therefore been subject to the Act’s obligations at all, was left entirely to regulations that were never finalized while the bill sat in committee. This is not a criticism invented after the fact — it is a structural feature of the bill as written, visible on its own face.

What a “high-impact system” would have had to do

Assuming a system had been designated high-impact by regulation, the bill would have imposed concrete, staged duties. A person responsible for such a system “must, in accordance with the regulations, establish measures to identify, assess and mitigate the risks of harm or biased output that could result from the use of the system” (Bill C-27, cl.8). A person making such a system available for use “must, in the time and manner that may be prescribed by regulation, publish on a publicly available website a plain-language description of the system” (cl.11(1)). And a person responsible for one “must, in accordance with the regulations and as soon as feasible, notify the Minister if the use of the system results or is likely to result in material harm” (cl.12). Three distinct duties — assess and mitigate, disclose publicly, and report material harm — each one, again, dependent on regulations that would still have needed to be written.

Who would have enforced it: not an independent commissioner

The Act would have created an Artificial Intelligence and Data Commissioner, but the bill’s own text is precise about what that role is: “The Minister may designate a senior official of the department over which the Minister presides to be called the Artificial Intelligence and Data Commissioner, whose role is to assist the Minister in the administration and enforcement of this Part” (Bill C-27, cl.33(1)). That is a delegate inside the Minister’s own department, assisting the Minister — not a structurally independent regulator in the mould of the Privacy Commissioner of Canada, who is an Agent of Parliament answering to Parliament rather than to a Minister. Anyone assuming AIDA would have created an arm’s-length AI watchdog is reading a role the bill did not actually create.

Where it stands, exactly

As recorded on LEGISinfo, read 27 August 2026, Bill C-27 is shown against the 44th Parliament, 1st session (22 November 2021 to 6 January 2025), a session the page itself marks as prior, with its status listed as “At consideration in committee in the House of Commons” and its latest recorded activity second reading and referral to committee on 24 April 2023 (LEGISinfo, Bill C-27). Report stage is marked “Not reached,” third reading “Not reached,” and Senate consideration “Not reached.” Everything past that sentence is speculation, and this piece will not offer any — the accurate answer to “is AIDA in force” is to quote exactly what Parliament’s own tracking page says, dated, rather than to guess at what a prior-session committee status implies about the future.

Related: how Canada regulates AI without an AI act and is there an AI registry in Canada.

Common questions

Is AIDA law in Canada right now?

The only accurate answer is what LEGISinfo itself records: Bill C-27 is shown against a prior session with its status at “consideration in committee in the House of Commons,” last active at second reading and referral to committee in April 2023. Neither “yes” nor “no, and it never will be” is something the tracking page itself states.

Would AIDA have applied to every AI system in Canada?

No — only to systems designated “high-impact” by regulations the bill left to be written later, and even then, Part 1 of the Act was scoped to AI systems used in the course of international or interprovincial trade and commerce, not every AI use nationwide.

Would AIDA have created an independent AI watchdog like the Privacy Commissioner?

No. The bill would have let the Minister designate a senior official inside the Minister’s own department as the Artificial Intelligence and Data Commissioner, assisting the Minister — a materially different structure from an Agent of Parliament answering independently to Parliament.

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