Questioning the Scope of Canada's AI Transparency Consultation Over Vague Objectives and Small Business Burdens

While the government's intention to consult on AI transparency is welcome, significant concerns remain about the design and potential impact of the exercise. The consultation questions are broad and open-ended, which risks producing vague or conflicting guidance that fails to address core accountability issues. For example, what counts as a 'high-impact' AI system remains undefined, leaving businesses uncertain about their obligations. Small and medium-sized enterprises (SMEs) are likely to bear a disproportionate burden, as they often lack the resources to implement complex transparency measures. Larger tech companies, by contrast, have teams dedicated to compliance and may even shape the rules to their advantage through intensive lobbying. There is also a risk that the consultation becomes a box-ticking exercise, with little real influence on policy if industry pressure mounts. Without specific mechanisms for enforcement or penalties for non-compliance, transparency requirements could become merely symbolic. Furthermore, the timeline for gathering feedback is relatively short, potentially excluding smaller groups that lack the capacity to prepare detailed submissions. A more targeted consultation with clear definitions and a phased approach for SMEs might have been more effective. As it stands, the process could produce rules that are either too weak to protect the public or too onerous for the businesses that power Canada's AI sector.