Canada’s AI Act died. Quebec’s rule is very much alive.

If you were tracking Canada’s federal AI bill — AIDA, inside Bill C-27 — you can stop. It died when Parliament was prorogued in January 2025, and no replacement is imminent. But “no federal AI law” isn’t “no AI law.” Quebec’s Law 25 has quietly required organizations to explain their automated decisions since 2023 — and it carries some of the sharpest privacy penalties in Canada.

What died, and what didn’t

AIDA and the rest of Bill C-27 died on the order paper with the January 2025 prorogation, and a federal AI statute isn’t close. Meanwhile, two things keep binding: Quebec Law 25’s automated decision-making provisions, in force since September 22, 2023, and PIPEDA, which continues to govern the use of personal data — including in AI — federally.

Quebec’s automated-decision duty

When a decision about an individual is based exclusively on automated processing, Law 25 requires the organization to inform the person — at or before the decision — and, on request, to disclose the personal information used, the principal factors and parameters that led to the decision, and the person’s right to have that information corrected. The individual may also submit observations to a member of staff who can review the decision. In plain terms: explainability, plus a human someone can actually appeal to.

Why it has teeth

Law 25 is not a soft-law framework. Its penalties run to CA$10 million or 2% of global revenue (administrative) and up to $25 million or 4% (penal) — a range comparable to the GDPR. That is enough to make automated-decision transparency a board-level concern for any organization touching Quebec residents.

For a U.S. company

If you make automated decisions about Quebec residents — credit, hiring, eligibility, pricing — you owe them an explanation and a route to human review. Build that capability once and it front-runs the explainability expectations you’ll meet under the EU AI Act and UK GDPR too. The dead federal bill is a distraction; the Quebec duty is the live one.

Canada shows a pattern you’ll see again: the comprehensive federal bill stalls, but a sub-national privacy law quietly imposes the duty that actually matters. In Canada, that duty is Quebec’s — explain the decision, and give people a human to appeal to.

This briefing is general information from Sentinel Assurance Group, not legal advice. Regulatory dates and requirements change — we maintain these briefings, but verify against primary sources and counsel before acting. Last reviewed July 22, 2026.

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