Share on LinkedInShare on LinkedIn

ARTICLE · 04 FEBRUARY 2026

Navigating Export Controls In The Clouds: Canada Clarifies Rules On Cloud Storage And Transfers

McCarthy Tétrault
McCarthy Tétrault
Contributor
McCarthy Tétrault

McCarthy Tétrault

Built on a unique model of collaboration, innovation and efficiency, McCarthy Tétrault delivers...

View firm profile
Explore more from McCarthy Tétrault

Canada's authority for administering export and technology transfer controls, Global Affairs Canada ("GAC"), has released Notice to Exporters No. 1159 – Guidance on the Movement to and Storage...

CanadaInternational Law

Canada's authority for administering export and technology transfer controls, Global Affairs Canada ("GAC"), has released Notice to Exporters No. 1159 – Guidance on the Movement to and Storage of Controlled Technology in the Cloud ("Guidance"), shedding light on a key question for businesses and academic researchers engaged in electronic transfers of controlled technology: When does using Canadian or foreign-based cloud services to store or transmit controlled technology trigger an "export" or "transfer" under Canadian export controls?

This long-awaited Guidance offers some important clarifications of GAC's position on these issues and how companies, researchers, and cloud service providers can approach compliance when leveraging cloud structures for sensitive technologies. With data routinely stored on servers located around the globe, determining when the use of cloud services results in the export or "transfer" of controlled technology, and therefore

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

See more popular content from