Do I have to tell people my product uses AI?

Canada’s proposed federal AI law died in January 2025, so there’s no single AI disclosure rule. Instead, disclosure duties come from privacy, employment and advertising law, depending on what your AI does. See is AI regulated in Canada for the wider picture.

When is disclosure required?

Situation	Rule	What to disclose
A decision about a person is made exclusively by automated processing, using their personal information	Quebec’s private sector privacy law, s. 12.1	That the decision was automated; on request, the information used and the main reasons and factors, and the right to have the information corrected; a way to submit observations to someone who can review the decision
Public job postings by Ontario employers with 25 or more employees	Employment Standards Act, since January 1, 2026	Whether AI is used to screen, assess or select applicants. See Ontario’s job posting rules
Personal information is used to train or run AI features	PIPEDA purposes, consent and openness principles	What you collect, why, and that it’s used for AI, in your privacy policy and at collection
Marketing claims about AI	Competition Act	Nothing specific, but claims about what the AI does, or that a human is involved, must not mislead

Do I have to label AI chatbots?

No statute in Ontario requires it in general. But presenting a bot as a human could be misleading in some contexts, and the Privacy Commissioner’s generative AI principles call for openness about when people are interacting with AI. Telling users up front also supports the disclaimers you rely on. See is my company liable for what its AI chatbot says.

Do I have to label AI-generated content?

Not under a general Canadian law. Platform rules can require it: YouTube and TikTok, for example, require creators to disclose realistic AI-generated or altered content. These rules change, so check the current version for each platform you post on. Brand deals increasingly ask creators to disclose AI edits too. If AI-generated images or reviews could mislead consumers about a product, the Competition Act applies.

What about selling to customers in the EU?

The EU AI Act has its own transparency obligations for some AI systems, which can apply to Canadian companies serving EU users. That’s outside Ontario law, but worth mapping if you sell there.

What should my terms and policies say?

• Your privacy policy should explain AI uses of personal information, including training.
• Your AI product terms should say output is AI-generated and may be inaccurate.
• If you make automated decisions about Quebec residents, build the notice and review process into the product.

What to do next

We draft AI product terms and privacy policies at fixed fees on our fees page. See also Quebec’s Law 25 for SaaS.

This guide is general information about Ontario and Canadian law, not legal advice for your situation. To check what your product should disclose, book a free 15-minute consult.