OpenMedia Bill C-27 AI Governance and Privacy Advocacy, Canada (2022–2025)

OpenMedia's campaign against Bill C-27 — Canada's Digital Charter Implementation Act, 2022 — was the first large-scale Canadian grassroots mobilisation on federal AI governance, mobilising nearly 40,000 community members and coordinating a coalition of 45 civil-society organisations over three years of parliamentary advocacy. The bill contained Canada's first attempt at comprehensive federal AI legislation in the Artificial Intelligence and Data Act (AIDA), alongside major overhauls to private-sector privacy law; OpenMedia opposed both the bill's substantive gaps and its structure, arguing that merging AI regulation into a privacy bill denied each set of issues the independent parliamentary scrutiny they required. The campaign ran from the bill's introduction on 16 June 2022 until Parliament's prorogation on 6 January 2025 killed all pending legislation, including C-27, without a vote.

Bill C-27 and the AIDA framework

Bill C-27 bundled three interconnected pieces of legislation: the Consumer Privacy Protection Act (CPPA), replacing the outdated private-sector privacy framework (PIPEDA) with consent-based protections and a strengthened enforcement authority; the Artificial Intelligence and Data Act (AIDA), Canada's first federal AI regulatory framework, adopting a risk-based approach requiring operators of "high-impact" AI systems to identify, assess, and mitigate risks of harm and bias; and the Personal Information and Data Protection Tribunal Act, establishing an independent appeals body. AIDA vested primary AI oversight in the Minister of Innovation, Science and Economic Development Canada (ISED) and proposed an AI and Data Commissioner operating under that department — the structural arrangement that civil society argued created a conflict of interest, given ISED's concurrent industry-promotion mandate.

Campaign launch and initial mobilisation (June 2022)

OpenMedia's response to the bill was immediate. On introduction day, 16 June 2022, OpenMedia published its initial assessment, with Campaigns Director Matt Hatfield declaring the bill "a tremendous disappointment": "The government has had nearly two years to learn from the mistakes of their 2020 bill — yet today's privacy bill repeats most of the same mistakes, with only minor improvements at the edges." By launch, OpenMedia had already accumulated 29,500+ petition signatures and 17,800+ messages to ministers on privacy protection from prior campaigns — the mobilisation infrastructure that would power the C-27 advocacy. Two core structural gaps anchored the critique from the start: the bill contained no meaningful limits on the data-broker economy and the commercial sale of personal data; and it lacked any recognition that privacy constitutes a fundamental human right rather than a consumer-protection issue, a framing OpenMedia had carried through prior advocacy on Bill C-11 and the 2020 predecessor legislation.

Community input and INDU submission (2023)

As Parliament's Standing Committee on Industry and Technology (INDU) took up the bill, OpenMedia converted its membership mobilisation into a formal submission. By May 2023, nearly 40,000 OpenMedia community members had contributed input to the submission, which called for maintaining and strengthening existing privacy protections, developing comprehensive and independent AI regulations, and addressing the structural flaw of housing AI governance exclusively within ISED. The process gave the campaign one of its defining characteristics: a community input pipeline that translated grassroots member engagement directly into parliamentary documentation, placing constituent perspectives — rather than exclusively expert or industry testimony — on the committee record.

September 2023 coalition open letter and committee testimony

With the INDU committee scheduled to begin its clause-by-clause study of the bill on 26 September 2023, a coalition of 45 civil-society organisations, experts, and academics released an open letter demanding proper parliamentary treatment for AI regulation. The signatories included the International Civil Liberties Monitoring Group, Canadian Civil Liberties Association, Public Interest Advocacy Centre, BC Civil Liberties Association, and University of Toronto Professor Emeritus Andrew Clement. The letter advanced five recommendations: (1) recognise privacy as a fundamental human right; (2) remove AIDA from ISED's exclusive jurisdiction to prevent a conflict of interest between AI promotion and AI oversight; (3) address vague AIDA language that created regulatory loopholes; (4) expand stakeholder consultation beyond industry insiders to include civil society, affected communities, and international perspectives; and (5) extend AI regulation to both the public and private sectors.

OpenMedia testified before the INDU committee on 2 November 2023 as part of the formal witness sessions. The campaign also supplied a detailed written submission to the committee documenting the specific amendments needed to address its five concerns. By this point, OpenMedia's combined C-27 and AI-governance community engagement had produced 10,000+ contacts to government on AI and facial recognition over two years.

The bill's death and legacy

Bill C-27 passed second reading in the House of Commons on 24 April 2023 and was referred to INDU, which conducted witness hearings through late 2023 and into 2024 before a clause-by-clause review began. The bill never reached a floor vote. When Prime Minister Trudeau announced his resignation in early January 2025, Parliament was prorogued on 6 January 2025, killing all pending legislation on the Order Paper. A broader coalition of opponents encompassing the Canadian Labour Congress, Writers Guild of Canada, Directors Guild of Canada, Amnesty International, and Assembly of First Nations had documented structural failings — vague scope, exclusionary consultation, insufficient protections for vulnerable groups — across the bill's parliamentary lifetime. The successor Parliament did not reintroduce AIDA in its original form.

The C-27 campaign's place in the wider Canadian AI-governance record is to have established what coordinated civil-society opposition to AI legislation looks like at the federal level: community-funded petition infrastructure, formal parliamentary submission backed by tens of thousands of constituent inputs, a cross-sector coalition documented on the INDU record, and sustained messaging that linked AI regulation to the prior digital-rights campaigns on surveillance and privacy that had won concrete CRTC reversals. OpenMedia's subsequent AI governance work — including the 2026 campaigns on AI and democracy before the Senate Standing Committee on Transport and Communications — built on the C-27 parliamentary record.