# I run a small Canadian technology company that provides messaging and cloud services, and I am concerned about Bill C-22, the Lawful Access Act, 2026,?

- Jurisdiction: Canada
- Practice area: Consumer Law
- Published: 2026-10-31
- Last updated: 2026-10-31
- Canonical: https://lawasked.com/ca/consumer-law/i-run-small-canadian-technology-company-provides-messaging

## Question

I run a small Canadian technology company that provides messaging and cloud services, and I am concerned about Bill C-22, the Lawful Access Act, 2026, which passed the House of Commons in June 2026 and is now before the Senate. I understand the bill would require electronic service providers to retain certain transmission metadata, build surveillance capabilities into their systems, and keep ministerial orders confidential. What would my company have to do if the bill passes in its current form, and what protections exist for encryption and user privacy?

## Summary

Based on the provided statutes, it is not possible to determine your specific obligations under Bill C-22, as the provided text only covers the Competition Act, the Canadian Human Rights Act, and the Canada Labour Code.

## Analysis

I cannot provide a definitive answer regarding what your technology company must do if Bill C-22 passes. The legal documents provided for this analysis consist of the Competition Act, the Canadian Human Rights Act, and the Canada Labour Code. None of these statutes contain the text or requirements of the proposed 'Bill C-22, the Lawful Access Act, 2026.'

While the Competition Act contains definitions for terms relevant to your business, such as "electronic message" (a message sent by any means of telecommunication, including a text, sound, voice or image message) [1] and "data" (representations, including signs, signals or symbols, that are capable of being understood by an individual or processed by a computer system or other device) [1], these definitions do not outline the surveillance or data retention mandates you are concerned about. Furthermore, the Competition Act includes rules regarding "false or misleading representation in the sender information or subject matter information of an electronic message" [2], but this relates to marketing and consumer protection rather than government lawful access or surveillance capabilities.

Because the specific text of Bill C-22 is missing from the available statutory sections, the protections for encryption and user privacy under that specific bill are also unknown. The law is currently unsettled in this context because the governing legislation for your specific question has not been provided.

Please note that federal, provincial, or local laws may add further rules regarding data privacy and telecommunications.

## Statutory citations

- Competition Act, R.S.C., 1985, c. C-34, s. 2 - Definitions [in force] (https://laws-lois.justice.gc.ca/eng/acts/C-34/index.html#s-2)
  > electronic message means a message sent by any means of telecommunication, including a text, sound, voice or image message
- Competition Act, R.S.C., 1985, c. C-34, s. 52.01 - False or misleading representation — sender or subject matter information [in force] (https://laws-lois.justice.gc.ca/eng/acts/C-34/index.html#s-52.01)
  > No person shall, for the purpose of promoting, directly or indirectly, any business interest or the supply or use of a product, knowingly or recklessly send or cause to be sent a false or misleading representation in the sender information or subject matter information of an electronic message.

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