This article looks at what C-27 promised, what its collapse means in 2025, and how CookieScript can keep you covered in the meantime.

Why's Bill C-27 Important?

Bill C-27 was meant to be Canada’s privacy reset. It would have scrapped PIPEDA (from 2000) and brought in the CPPA, plus the AIDA for high-impact AI. No federal bill had ever tried to bundle privacy and AI together.

When it collapsed in January 2025, the ideas didn’t vanish. Consent, stronger rights, AI checks—these are now seen as inevitable. Regulators and lawyers talk as if the rules are already coming. If you’re waiting for Ottawa to pass a new bill, you may already be behind.

Meanwhile, Quebec’s Law 25 has taken over the spotlight. Passed in 2021 and rolled out in three steps—Sept 2022, Sept 2023, and Sept 2024—it now requires things like:

• Clear opt-in consent for sensitive data.
• PIAs before launching tech projects that touch personal data.
• Notices when automated systems affect someone’s rights.
• New powers for people to demand deletion or data transfer.
• Heavy penalties: up to CAD $25 million or 4% of global turnover.

Those numbers are close to what C-27 promised (its fines went as high as 5%). But Quebec moved first, and since Sept 2024 it’s enforceable. For now, it’s Quebec—not Ottawa—that sets the toughest privacy bar in Canada.

What Bill C-27 Proposed

Bill C-27 split into two pieces: the Consumer Privacy Protection Act (CPPA) for privacy and the Artificial Intelligence and Data Act (AIDA) for AI. Simple on paper, messy in practice.

CPPA (Consumer Privacy Protection Act)

It was supposed to go further than PIPEDA:

• A legal definition of “valid and meaningful” consent. No shortcuts with implied consent.
• Children’s data was called sensitive by default. Extra hoops.
• Fines? Up to CAD $25 million or 5% of global turnover. Pretty harsh. A new Personal Information and Data Protection Tribunal would have handled that.
• The Privacy Commissioner finally getting binding powers, instead of just “recommendations.”

AIDA (Artificial Intelligence and Data Act)

The AI side was new ground. Target was so-called high-impact systems — credit checks, hiring software, health tools. Requirements included:

• Risk programs and testing. (Not just once — ongoing.)
• Keeping documentation: datasets, design notes, fixes.
• Telling people when AI made a decision that mattered to them.
• A new AI and Data Commissioner to watch over it all.

Bill C-27 Off the Table

In January 2025, Parliament was prorogued and Bill C-27 officially died on the Order Paper. That move killed both the CPPA and the AIDA before they ever reached a vote.

A few months later, in April 2025, a snap federal election pushed privacy reform even further down the road. With a new session of Parliament and shifting priorities, there was no chance to re-table the bill in its original form.

The result is that Canada is still running on PIPEDA, a law written in 2000, with no federal framework for artificial intelligence. Businesses can’t wait around for Ottawa to catch up, so most now align their practices with stricter standards already in force — Quebec’s Law 25 at home and the GDPR abroad.

For many organizations, that means treating these tougher provincial and international rules as the real baseline, since federal law no longer sets the pace.

The Political Fallout of C-27

In January 2025, the federal government under Prime Minister Justin Trudeau prorogued Parliament. That move automatically killed every bill still in progress — including C-27. Both the CPPA and the AIDA disappeared from the agenda overnight.

Only a few months later, in April 2025, a snap federal election was called. With Parliament dissolved and priorities shifting to campaigning, privacy reform slipped off the table. Even after the election, re-tabling C-27 in its original form was no longer a political priority.

The result is that Canada is still operating under PIPEDA, written in 2000, with no federal AI law in place. That leaves the Office of the Privacy Commissioner underpowered and businesses without a clear national standard.

In practice, companies are leaning on stricter rules — Law 25 at home and the GDPR abroad — since Ottawa has yet to deliver a modern replacement.

Impacts on Businesses in 2025

The collapse of C-27 left companies without a clear federal roadmap. With PIPEDA still in place, they’re juggling uneven rules and growing demands from regulators and customers. The impact looks different depending on who you are.

SMEs

For small and mid-sized businesses, the hardest part is uncertainty. They know PIPEDA is out of date, but their clients expect more. A small retailer with customers in Quebec, for instance, has to follow Law 25 even if federal law says less.

Few SMEs have compliance teams, so they lean on scalable consent tools — banners that block cookies until users click, logs that prove consent, privacy notices they can update without lawyers. Without those, even running a simple site feels risky.

Large platforms

Big players don’t wait. They already build to GDPR standards because that’s the price of staying global. In Canada, it’s about keeping things consistent — running the same consent flows everywhere, extending Google Consent Mode v2 beyond Europe, and assuming any future Canadian law will track closely with the EU’s model.

Regulators

The OPC is still bound by PIPEDA, which keeps its powers limited. That gap lets provinces move in. Law 25 is already in force, and other provinces are watching. The signal is clear: waiting for weak federal enforcement is a bad bet.

The Role of a CMP — Preparing for the “next” Bill C-27

C-27 is gone, but the ideas inside it — stronger consent, stricter rules, more accountability — are what regulators expect now. Businesses can’t hide behind PIPEDA. They need tools that already line up with GDPR, CPRA, LGPD, KVKK, POPIA and others.

That’s where CookieScript comes in. It’s a G2 badge, built to handle consent the way regulators actually want it done.

What it does:

• Blocks Third-Party Cookies until people say yes.
• Keeps a log of every consent and turns that into reports you can hand to regulators.
• Switches banners automatically for Canada, Quebec, or anywhere else.
• Works in 40+ languages, including English and French out of the box.
• Runs on Google Consent Mode v2 and supports IAB TCF 2.2.
• Scans your site every month, spots new cookies, and blocks them until consent is there.
• Privacy Policy Generator plus a Cookie Policy Generator, so you’re not left copying boilerplate.
• Lets you host the code yourself or share banners across projects.

In Spring 2025, CookieScript was awarded its fourth consecutive G2 badge for Best Consent Management Platform.

That mix gives small businesses a way to stay safe without lawyers on retainer — and big platforms a way to keep things consistent across markets.

What the Future Holds — “Bill C-27 is not gone”

In June 2025, Minister Evan Solomon made it clear that C-27 will not return in its old form. He confirmed that the AIDA is off the table as drafted, and only parts of it may survive in a new framework.

Solomon stressed a “light, tight, right” approach to AI regulation — light enough to avoid stifling innovation, tight enough to close real risks, and right-sized for Canada’s economy. Privacy reform, too, will need re-examination rather than a straight reintroduction of the CPPA.

For businesses, the signal is obvious: treat C-27 as a preview, not a failure. Its core themes — valid consent, stronger enforcement, and AI accountability — will shape whatever comes next.

Preparing now with GDPR-level practices, automated consent tools, and cross-jurisdiction compliance is safer than waiting for Ottawa to move.

Challenges and Criticism

Bill C-27 was never bulletproof. The AIDA drew fire for being vague on “high-impact” — the bill left the term hanging, to be defined later. That gave businesses no clue what systems would actually be covered.

For SMEs, the complexity was another headache. Few have compliance officers; most would be left guessing how to keep up.

Overlap was another sticking point. Law 25 already sets strict rules in Quebec, and C-27 risked layering federal rules on top of that. Instead of clarity, companies feared double compliance.

Meanwhile, Canada looks behind. Europe has the GDPR and an AI Act. The U.S. has state laws and a White House directive. Here? Still PIPEDA, written in 2000. No federal AI law.

So now we’re stuck with a patchwork. Quebec enforces Law 25, other provinces could follow, and Ottawa has nothing ready.

For businesses, that means rules depend on the customer’s postal code. It’s messy, and until Ottawa acts, it’s not changing.

In Conclusion

Canada had a chance to lead, and instead it hesitated. That pause won’t stop regulators abroad — or provinces at home — from raising the bar.

Businesses that treat compliance as a waiting game will lose ground, not just legally but in trust.

The smarter play is to act as if the next bill is already here and to prove, now, that respecting data and consent isn’t a burden — it’s table stakes.

Frequently Asked Questions

Do I still need to follow GDPR in Canada if Bill C-27 is dead?

Yes. If you handle data from EU residents, GDPR applies regardless of Canadian law. Many Canadian businesses just use GDPR as their baseline everywhere. CookieScript makes this easier with consent flows, cookie blocking, and audit logs that meet GDPR standards.

How do I stay compliant with Quebec’s Law 25 and PIPEDA at the same time?

Law 25 is stricter than PIPEDA, so if you serve Quebec users, you need to follow it. CookieScript handles this automatically with geo-targeting, so Quebec visitors see a Law 25–compliant banner, while others see the right version for their region.

What does Canada’s lack of an AI law mean for my business?

It means there’s no single national rulebook. You’ll have to watch for global standards like the EU AI Act or U.S. directives. CookieScript helps reduce risk by ensuring personal data used in AI systems is only collected after valid consent, via Google Consent Mode v2 and IAB TCF 2.2.

Do small businesses really need a CMP in Canada?

Yes. Even a basic website that drops Third-Party Cookies needs valid consent. Law 25 and GDPR don’t care about company size. CookieScript gives SMEs affordable tools — automatic scans, cookie blocking, and a built-in Privacy Policy Generator — so they can comply without hiring a lawyer.

Is PIPEDA enough to keep me compliant in 2025?

Not really. PIPEDA hasn’t been updated since 2000 and doesn’t match today’s expectations. Customers and provincial regulators expect GDPR-style protections. CookieScript’s consent logs and reporting let you prove compliance at a higher standard than PIPEDA alone requires.

Do Canadian regulators actually check for consent compliance?

The OPC has limited powers, but provincial regulators like Quebec’s CAI do enforce Law 25. And global partners (Google, Meta) demand consent standards already. CookieScript’s reporting and audit logs give you proof if anyone asks.

Do I need to worry about U.S. or international privacy laws if I only operate in Canada?

If you have users from those regions, yes. And big platforms expect global compliance anyway. CookieScript supports GDPR, CCPA, LGPD, KVKK, POPIA, and PIPEDA in one system, so you don’t have to juggle separate tools.