European Union (AI Act) vs Canada

Dimension

European Union (AI Act)

Canada

Status

In Effect (phasing in)

No federal AI Act (AIDA lapsed)

Max penalty

Up to €35M or 7% of global turnover

No federal AI-specific penalty; Quebec Law 25 up to CAD $25M or 4% of global turnover

Key deadline

High-risk obligations from August 2, 2026

Federal AI bill lapsed; Treasury Board Directive legacy-system compliance by June 24, 2026

# of instruments

4

4

Headline rule

EU AI Act (Regulation 2024/1689)

PIPEDA — Personal Information Protection and Electronic Documents Act

What it requires

The EU AI Act is the world's first comprehensive horizontal AI law, applying a risk-based regime across all 27 member states — and to any company serving EU users. Prohibited-use bans already apply; high-risk system obligations (conformity assessment, technical documentation, human oversight) phase in through August 2, 2026.

Contrary to common reporting, Canada has no enacted federal AI statute — Bill C-27, which contained the Artificial Intelligence and Data Act (AIDA), died when Parliament was prorogued in January 2025 and has no successor as of 2026. AI is governed indirectly through PIPEDA (federal privacy law), the Treasury Board Directive on Automated Decision-Making (which requires federal agencies to run algorithmic impact assessments), and provincial laws such as Quebec's Law 25, which requires disclosure of automated decisions, an explanation of the logic, and a right to human review.