ICTC welcomes the Government of Canada’s consultation on measures to improve, strengthen, and increase AI transparency. Clear and proportionate transparency requirements can strengthen public confidence, improve business adoption, support regulatory oversight, and give Canadians meaningful ways to understand and address the consequential uses of AI.

To support the Government of Canada in its efforts to advance AI transparency and create the regulatory, policy, and governance frameworks required to strengthen trust in AI, ICTC has developed this response to four specific areas of the Government’s consultation: AI Interaction, Information about AI Systems, AI Incidents, and AI Agents.

To achieve the Government of Canada’s objectives of enhancing Canadians’ understanding and trust in AI, ICTC has outlined a series of ten mutually reinforcing recommendations.

Recommendations

  1. Adopt a risk-based, role-based, and context-sensitive framework. Transparency obligations should reflect the AI system's function, its deployment setting, the degree of assigned authority, and the potential consequences on people and organizations.
  2. Create a meaningful right to be informed. Canadians should receive clear notice when they interact directly with AI or when AI materially influences a consequential decision, service, or process affecting them.
  3. Standardize layered information about AI systems. Canada should develop adaptable documentation that serves individuals, business adopters, auditors, researchers, and regulators without requiring indiscriminate public disclosure of sensitive information.
  4. Establish a coordinated AI incident reporting and learning framework. Serious incidents should be reported through a common framework that complements existing sectoral regimes, protects confidentiality, and publishes anonymized lessons and disclosures to enhance trust.
  5. Implement Graduated Autonomy and Agency for AI agents. Authority delegated to AI agents should expand or contract according to demonstrated performance, risk, context, and the consequences of the actions an AI agent is permitted to take.
  6. Develop the trust layer for the AI agent economy. The widespread creation and adoption of AI agents is creating new terrains for Canada should lead on AI agent identity and credentials, progressive authorization, delegation protocols, activity evidence, assurance, interoperability, and revocation.
  7. Use standards, assurance, sandboxes, and procurement. Legislation should be supported by technical standards, independent verification, supervised experimentation, and federal purchasing requirements to ensure that transparency requirements are proportionate, relevant, and agile enough to address the rapid development of AI.
  8. Provide proportionate pathways for SMEs to catalyze adoption. Governance templates, technical assistance, shared tools and resources, phased requirements, and trusted advisory services should reduce compliance costs while supporting responsible AI adoption.
  9. Invest in AI literacy and governance capacity. Workers, consumers, businesses, and public institutions need the skills to interpret disclosures and act on them. They also need the foundational AI literacy to understand how AI works, how their sensitive and private data is handled, and the measures they can take to protect their privacy while using AI safely and responsibly.
  10. Coordinate across jurisdictions and evaluate outcomes. Federal measures should align with provincial, territorial, and international frameworks and be assessed for comprehension, contestability, risk reduction, and accountability. Canada should look to trusted partners to align regulatory frameworks to enhance interoperability and reduce barriers to businesses.

Read ICTC’s full written submission to the Government of Canada’s public consultation on AI transparency

To cite this publication:

Information and Communications Technology Council (ICTC). (2026, September 23). Enhancing Trust in Artificial Intelligence Through Increased Transparency: The Information & Communications Technology Council's Submission to the Government of Canada's Public Consultation on AI Transparency.