
As artificial intelligence (AI) becomes increasingly embedded in business operations, online content, and consumer-facing services, Canadians may not always know when AI is being used, whether content has been generated using or altered by AI, or how to assess an AI system’s capabilities and limitations. As a result, ensuring there is clear transparency on when AI is being used is a key issue for organizations, consumers, and policymakers.
The Government of Canada is now seeking input on these issues through a public consultation on AI transparency, launched on July 23, 2026. The consultation will remain open until September 23, 2026.
The consultation forms part of Canada’s National Artificial Intelligence Strategy: AI for All, which was launched on June 4, 2026, and is intended to support responsible AI adoption, build public trust, and strengthen Canada’s digital sovereignty. (For our earlier commentary on the strategy, see Canada’s AI Strategy Starts but Falls Short on Ensuring Patent Protection for AI Inventions and Canada’s AI Strategy Leaves Copyright Issues Unaddressed.)
The government is currently seeking input from Canadians, Canadian residents, businesses, researchers, civil society organizations, Indigenous groups, and other stakeholders on several transparency-related issues, including:
identifying and detecting AI-generated content, including what form transparency should take, and options for labelling AI-generated content;
helping individuals know when they are interacting with an AI system;
improving access to understandable information about AI systems, including their development, capabilities, and limitations;
enabling the tracking of serious incidents involving AI systems; and
developing approaches to track the activities and interactions of AI agents.
Taken together, these areas point to the practical challenges of making AI systems and AI-generated outputs more identifiable, explainable, and accountable. The discussion paper frames transparency as an important foundation for individuals to be informed of Ai-generated content and to make informed decisions on their use of AI, and towards AI being used safely and responsibly by individuals and businesses while recognizing that transparency alone will not address all AI-related risks.
For businesses, the consultation may signal future expectations around AI governance, disclosure, including labelling AI-generated content, record-keeping, and incident reporting. Organizations that develop, procure, or deploy AI systems, and that use AI to generate content, may wish to monitor the consultation closely, particularly if they use AI in customer-facing tools, content generation, automated decision-making, or agentic systems that can take actions on behalf of users.
The consultation gives Canadian businesses and other stakeholders an opportunity to help shape the next phase of Canada’s AI policy framework, through sharing their own experiences and thoughts, including how transparency expectations may develop in practice.
If you have questions about the consultation or the legal implications of developing, procuring, or deploying AI systems in Canada, please contact a member of our Canadian team.
This article is provided for general information and does not constitute legal advice.
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