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ARTICLE · 23 OCTOBER 2026

M&A Lawyers Take Note: What Bill C-36 Could Mean For Transactions

Bennett Jones LLP
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Bill C-36 proposes sweeping changes to Canada's privacy landscape through the Protecting Privacy and Consumer Data Act, introducing penalties up to $25 million and private rights of action for non-compliance. How will these unprecedented enforcement mechanisms reshape M&A due diligence, contractual protections, and risk allocation in transactions involving personal data?

CanadaCorporate/Commercial Law
Ruth Promislow
Ruth Promislow
J. Sébastien Gittens
J. Sébastien Gittens
Suzie Suliman
Suzie Suliman
Morgan Sutherland
Morgan Sutherland
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In June 2026, the federal government introduced Bill C-36 to enact the Protecting Privacy and Consumer Data Act (PPCDA). A key change from the current regulatory regime is the prospect of significant liability arising from non-compliance. This key change could materially affect the privacy risks associated with M&A transactions in such a way that transaction parties may need to revisit both: (i) the scope of privacy-related due diligence; and (ii) the contractual protections negotiated to address those risks.

This blog examines some of the key considerations for dealmakers as they assess the potential implications of the PPCDA in the context of M&A transactions.

New Risks under Proposed Legislation

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