United States (federal) vs Canada

Dimension

United States (federal)

Canada

Status

State-led (no federal Act)

No federal AI Act (AIDA lapsed)

Max penalty

Varies by state & agency; up to $5,000/day per violation (California)

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

Key deadline

Rolling — state deadlines through 2026–2027

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

# of instruments

3

4

Headline rule

No comprehensive federal AI statute

PIPEDA — Personal Information Protection and Electronic Documents Act

What it requires

The US has no single federal AI law. Binding obligations come from a patchwork of state statutes — California, Colorado, Illinois, Texas and others — overlaid with sectoral federal enforcement by the FTC, EEOC, CFPB and FDA. Multistate operators must comply with the strictest applicable state rule.

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.