Canada Tables Bill C-36 to Replace PIPEDA: What the Privacy Reform Bill Would Change

By Recording Law Editorial Team8 min read
Canada Tables Bill C-36 to Replace PIPEDA: What the Privacy Reform Bill Would Change

Frequently Asked Questions

Is Bill C-36 now Canada's privacy law?

No. As of June 20, 2026, Bill C-36 has only received first reading, which it got on June 15, 2026. It is a proposed law that still has to pass second reading, committee study, third reading, the Senate, and Royal Assent before it could take effect. Canada's federal private-sector privacy law remains PIPEDA.

What happened to Bill C-27?

Bill C-27 was the previous federal privacy reform package, which also would have created a Consumer Privacy Protection Act and included an Artificial Intelligence and Data Act. It reached committee study, with its last recorded committee meeting on September 26, 2024, but it died on the Order Paper when Parliament was prorogued in January 2025 without a final vote.

What new regulator would Bill C-36 create?

The bill would establish the Digital Safety and Data Protection Commission of Canada, which would include a Privacy and Consumer Data Commissioner and a Privacy and Consumer Data Division. According to the bill text, the Commission would have the power to issue orders and impose administrative monetary penalties, stronger enforcement tools than PIPEDA currently provides.

Does Bill C-36 regulate artificial intelligence?

No. Unlike Bill C-27, Bill C-36 does not include a standalone Artificial Intelligence and Data Act. The government separated privacy reform from AI regulation in this package, leaving any federal commercial AI framework for separate legislation.

What is Quebec's Law 25 data portability right?

It is a provincial right, in force since September 22, 2024, that lets Quebec residents obtain the computerized personal information an organization collected from them in a structured, commonly used technological format, and have it transmitted to themselves or another authorized organization. It is part of Quebec's Law 25 reform of the Act respecting the protection of personal information in the private sector.

What should businesses do while Bill C-36 is pending?

Continue to comply with the laws actually in force. Federally that means PIPEDA, and in Quebec it means Law 25, which already imposes mandatory breach reporting, strict consent rules, a data portability obligation, and large administrative monetary penalties. Organizations should monitor Bill C-36's progress through Parliament and prepare for tighter consent, transparency, and enforcement standards if it passes.

Sources and References

  1. Parliament of Canada, LEGISinfo: Bill C-36 (45-1), An Act to enact the Protecting Privacy and Consumer Data Act, showing introduction and first reading on June 15, 2026 and sponsor Evan Solomon, Minister of Artificial Intelligence and Digital Innovation(parl.ca).gov
  2. Parliament of Canada, Bill C-36 first reading text, establishing the Digital Safety and Data Protection Commission of Canada, a Privacy and Consumer Data Commissioner, the fundamental-right framing, and powers to issue orders and administrative monetary penalties(parl.ca).gov
  3. Office of the Privacy Commissioner of Canada: Statement by Commissioner Philippe Dufresne on Bill C-36, dated June 15, 2026, welcoming the bill and the recognition of privacy as a fundamental right and the best interests of children(priv.gc.ca).gov
  4. Parliament of Canada, LEGISinfo: Bill C-27 (44-1), the Digital Charter Implementation Act package (CPPA, Personal Information and Data Protection Tribunal Act, and AIDA), showing committee consideration with a last meeting on September 26, 2024 and that the session ended in January 2025(parl.ca).gov
  5. Office of the Privacy Commissioner of Canada: overview of PIPEDA confirming it is the federal private-sector privacy law setting the ground rules for how organizations collect, use, and disclose personal information in commercial activities(priv.gc.ca).gov
  6. Commission d'acces a l'information du Quebec: news confirming the Law 25 data portability provisions came into force on September 22, 2024, requiring organizations to communicate computerized personal information in a structured, commonly used technological format(cai.gouv.qc.ca).gov
  7. Commission d'acces a l'information du Quebec: main changes brought by Law 25, including breach reporting, consent rules, mandatory data protection officers, and administrative monetary penalties up to the greater of 10 million dollars or 2 percent of worldwide turnover(cai.gouv.qc.ca).gov
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