The CRTC last week released the first three of at least nine planned consultations on the implementation of Bill C-11 (I was out of the country teaching an intensive course so playing catch-up right now). The consultations focus on the broad structure of the regulatory framework, registration requirements, and transitions from the current system of exemptions to one of regulations. The timeline to participate in this consultation is extremely tight with comments due as early as June 12th for two of the consultations and June 27th for the larger regulatory framework one. As the title of this post suggests, the CRTC is adopting an approach of shoot first, aim later. The consultations suggest that there is little interest in hearing from anyone outside of the legacy groups that have long dominated CRTC hearings. Indeed, by moving forward with incredibly tight timelines, without the government’s promised policy directive, and without support for newer groups to back their participation, the documents leave the distinct impression that the Commission had surrendered its independence and already made up its mind on how to implement Bill C-11.
Archive for May 18th, 2023

Law Bytes
Episode 275: David Loukidelis on Why Stripping Privacy Enforcement from Canada’s Privacy Commissioner in Bill C-36 is Unnecessarily Risky Policy
byMichael Geist

June 22, 2026
Michael Geist
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Michael Geist on Substack
Recent Posts
Why Being Locked Out of Frontier AI is The Sovereignty Threat Canada Missed
Blocked Twice: How Bill C-34’s Kids’ Social Media Ban Would Compound the Online News Act’s Harm to Young Canadians’ News Access
The Law Bytes Podcast, Episode 275: David Loukidelis on Why Stripping Privacy Enforcement from Canada’s Privacy Commissioner in Bill C-36 is Unnecessarily Risky Policy
The Data on Australia’s Social Media Ban: The Better the Privacy Protection, The Less Effective the Ban
Shaky Ground Gets Shakier: What the U.S. Supreme Court’s Location Data Decision Means for Bill C-22

