Under the Canadian Artificial Intelligence and Data Act, when must the Minister of Innovation, Science and Industry be notified about a high-impact…

The Canadian Artificial Intelligence and Data Act (AIDA), as proposed in Bill C-27, establishes a specific trigger for notifying the Minister of Innovation, Science and Industry. According to Section 15(1) of the Act, a person responsible for a high-impact system has a legal obligation to notify the Minister "as soon as feasible" if they have reasonable grounds to believe that the use of the system has resulted in, or is likely to result in, "material harm." This is a reactive, incident-based reporting requirement focused on significant negative outcomes, rather than a procedural notification tied to the system's lifecycle stages like deployment or assessment completion.

B. When the algorithmic impact assessment has been completed.

An assessment is a required internal due diligence process, but the Act does not mandate notifying the Minister upon its completion, though records must be kept.

C. Upon release of a new version of the system.

The Act does not specify a notification requirement for every new version; obligations regarding risk management and transparency apply continuously to the system in operation.

D. Upon initial deployment of the system.

The Act requires publishing a public description of the system (Section 10), not directly notifying the Minister upon initial deployment. The explicit notification trigger is harm.

1. Government of Canada

Bill C-27 (2022). An Act to enact the Consumer Privacy Protection Act

the Personal Information and Data Protection Tribunal Act and the Artificial Intelligence and Data Act and to make consequential and related amendments to other Acts. Part 3

Section 15(1). "A person who is responsible for a high-impact system must

as soon as feasible

notify the Minister if the use of the system results in or is likely to result in material harm." (https://www.parl.ca/DocumentViewer/en/44-1/bill/C-27/first-reading)

2. Innovation

Science and Economic Development Canada (ISED). The Artificial Intelligence and Data Act (AIDA) - Companion document. Section: "Accountability - Reporting on harms." "AIDA would require those responsible for a high-impact system to notify the Minister when they have reasonable grounds to believe that the use of the system has resulted in or is likely to result in material harm (clause 15)." (https://ised-isde.canada.ca/site/digital-charter-implementation-act/en/artificial-intelligence-and-data-act-aida-companion-document)

3. Scassa

T. (2022). Canada’s Proposed Artificial Intelligence and Data Act: A Reading. University of Ottawa

AI + Society Initiative. Page 10. "Section 15 contains a requirement to notify the Minister 'as soon as feasible' if the use of a high-impact system 'results in or is likely to result in material harm'." (https://www.aiss-siaa.ca/wp-content/uploads/2022/06/AIDA-Commentary-Scassa-June-20-2022.pdf)