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Bill C-36, what may replace PIPEDA.

Canada’s third attempt at modernizing federal private-sector privacy law was tabled in June 2026. It is not law yet, but its direction is clear enough to start planning.

Bill C-36 in brief.

Type
Federal bill (proposed law)
Short title
Protecting Privacy and Consumer Data Act
Tabled
2026-06-15, House of Commons (45th Parliament, 1st session)
Sponsor
Minister of Artificial Intelligence and Digital Innovation
Stage
Second reading (as of 2026-10-03)
Status
Not in force

What, why and who.

What it is

Bill C-36 would enact the Protecting Privacy and Consumer Data Act and replace Part 1 of PIPEDA; the electronic-documents parts of PIPEDA would remain. It recognizes privacy as a fundamental right and the best interests of children, requires privacy management programs and impact assessments for higher-risk uses, and adds stronger enforcement.

Why it exists

PIPEDA dates from 2000 and relies on an ombudsman model without administrative penalties. Two earlier reform bills, C-11 (2020) and C-27 (2022), died on the order paper. C-36 is narrower than C-27: it drops the separate tribunal and the artificial-intelligence act.

Who it applies to

If passed, the same organizations as PIPEDA Part 1: private-sector organizations in commercial activity across borders and federally regulated businesses. Quebec businesses would continue to deal mainly with Law 25 for in-province activity.

Authority and enforcement

According to the Office of the Privacy Commissioner, oversight of private-sector privacy would move to a new Digital Safety and Data Protection Commission of Canada, created by the related Bill C-34, with power to issue orders and administrative penalties. Some summaries describe the design differently; the final text will govern.

How it got here.

  1. 2020-11-17

    Bill C-11 (Digital Charter Implementation Act) is introduced; it dies at dissolution in 2021.

  2. 2022-06-16

    Bill C-27 proposes the Consumer Privacy Protection Act, a tribunal and an AI act.

  3. 2025-01-06

    Parliament is prorogued and C-27 dies.

  4. 2026-06-10

    Bill C-34 (Safe Social Media Act) is tabled, creating the commission C-36 relies on.

  5. 2026-06-15

    Bill C-36 is tabled at first reading. The OPC issues a statement the same day.

What it changes.

Systems and tools

  • Data mobility (portability) between organizations
  • Re-identification controls for de-identified data
  • Explanations for automated decisions with significant effects

Processes

  • Impact assessments for high-risk uses and cross-border transfers
  • A higher standard of care for minors’ information
  • Use of a new legitimate-interest exception, with documentation

Governance

  • A privacy management program that can be produced to the regulator on request
  • Board-level oversight of privacy risk
  • Contract and vendor updates once in force

If you do not comply

  • As proposed, administrative penalties up to $10 million or 3% of gross global revenue
  • As proposed, fines up to $25 million or 5% for the most serious offences
  • A private right of action after a contravention is found
  • Orders from the new commission

Changes ahead.

Announced and upcoming changes

  • NextSecond reading debate, then committee study in the House, then the Senate.
  • Coming into forceNot fixed. Commentators expect obligations to start some time after royal assent, with consultation on the transition to the new regulator.

Status checked 2026-10-03. Dates can move; confirm with the official sources below.

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