CanadaBill C-34, Safe Social Media Act (synthetic content labelling and chatbot transparency)
Bill C-34 An Act to enact the Digital Safety Act and the Digital Safety Commission of Canada Act and to make consequential amendments to other Acts, 45th Parliament, 1st Session, ss. 37, 53(a)
An AI transparency rule binding private bodies.
- How the hook was established
- express
- What makes it apply
- User location
- Audit expectation
- on_request
- Who audits it
- Regulator
What it requires
- Would require the operator of a regulated social media service, to the extent that it is reasonable for the operator to do so, to implement adequate measures to label, as synthetic content, any synthetic content accessible on the service that meets the criteria set by regulation.
- Would require a regulated AI chatbot service to implement measures adequate to mitigate the risk of the chatbot posing as a human being or otherwise being deceptive about being an artificial intelligence system.
These lines are LexLint's reading of the law's text.
In the frameworks
- NIST AI RMF
- MEASURE 2.8Risks associated with transparency and accountability – as identified in the MAP function – are examined and documented.
Our reading of where this law's duties sit in each framework. It never says that running a control meets the law. How we read a framework against the law
Who enforces it
Settledness
- As of
- Open questions
- Which synthetic content 'meets the criteria provided for by regulations' under subsection 37(1) of Bill C-34, given that the bill leaves those criteria to regulations that have not been made?
- Does the definition of synthetic content, which covers an 'audio representation or visual representation' only if the depiction is 'likely to be mistaken for an authentic audio or visual recording', reach AI-generated imagery that is plainly stylized rather than photorealistic?
- Is an artificial intelligence system built for a single task, such as customer support, a chatbot service when it is 'capable of being used, by means of multiple interactions or sessions, to simulate a sustained human-like relationship with a user' only because a user could prompt it that way?
What it makes you log
Who may demand the log
Regulator
Logging duty
Section 25 requires the operator of any regulated service to keep all records, including information and data, necessary to determine whether it is complying with its duties under the Act. Those duties include the synthetic-content labelling duty in s. 37 and the chatbot duty in s. 53(a), which carry no record clause of their own, so the duty reaches them only through s. 25. It says nothing about what the records must hold or for how long; the Commission may make regulations on the length of time the records must be kept and the types of record not required to be kept (s. 126(1)(e)). As a proposed bill this binds nobody yet.
- Kind
- Explicit
- As of
- Provision
- Digital Safety Act s. 25 (as enacted by Bill C-34 s. 2), read with ss. 37 and 53(a)
- Trigger
- all_systems
Why the legislator wanted it
Section 14(h) is a purpose of the Act as a whole; the record duty itself sits under the heading Duty to Be Transparent.
- As of
- Quote
- (h) ensure that operators are transparent and accountable with respect to their duties under this Act;
- Source link
- https://www.parl.ca/DocumentViewer/en/45-1/bill/C-34/first-reading
- Source kind
- Recital
- Purpose
- accountability_demonstration
- regulator_supervision
What this law does
Would require operators of regulated social media services to implement adequate measures to label, as synthetic content, any synthetic content accessible on the service that meets criteria set by regulation.
Separately, operators of regulated AI chatbot services would be required to implement measures adequate to mitigate the risk of the chatbot posing as a human being in a manner likely to lead a user to mistake it for one, or otherwise being deceptive about being an artificial intelligence system. Introduced . The same bill also sets a minors' account-access threshold researched separately under the age-verification topic.
When LexLint raises it
When your app profile says your app deploys a chatbot, operates a social platform, generates content with AI or serves under-18s.
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