Due Diligence Deskbook

Canada and Germany are making unprecedented investments in AI infrastructure and safety research, while major players like Cohere, OpenAI, and Bell position themselves in a rapidly evolving landscape of technology sovereignty. How will these strategic moves reshape the global AI race and what do they mean for businesses navigating data residency, vendor relationships, and emerging regulatory frameworks?

On January 1, 2004, the <I>Limitations Act, 2002</I> came into force in Ontario. This statute governs the limitation periods applicable to claims governed by the law of Ontario. The new statute makes significant changes to limitation periods generally. These changes will have a significant impact on claims related to pension matters.

Canadian organizations developing, acquiring, deploying or using AI have until September 23, 2026 to contribute to shaping the federal government's approach to AI transparency through a public consultation. Innovation, Science and Economic Development Canada is seeking input on five key areas that could lead to new disclosure obligations, incident reporting requirements, and AI agent tracking mechanisms.

The Canada Investment Summit generated nearly $500 billion in investment commitments, but the critical challenge now lies in converting this momentum into active development. This analysis examines the legal, commercial and strategic conditions required to move investment commitments toward execution, exploring how economic sovereignty, project readiness and sector-specific opportunities will shape Canada's path from capital allocation to operational delivery.

The idea that banks should invest in large-scale replacement of legacy systems has had some traction. Current core banking systems, replacement proponents suggest, are decades old and simply can't serve banks effectively anymore, on a host of levels.

Last week, the federal government unveiled AI for All, an ambitious national strategy designed to accelerate AI adoption from just over 12% today to 60% by 20341 while advancing trust, opportunity, and Canadian sovereignty as foundational principles for the country’s AI future.

Policy and business leaders in 2026 are confronting disruptive global forces that pose daunting economic and financial risks while also transforming markets and creating avenues for growth over the next years.

Jake Bullen has been appointed by the Law Society of Ontario to the Business Law Advisory Working Group.

Canada's AI for All strategy abandons the proposed Artificial Intelligence and Data Act in favor of a distributed governance model combining targeted legal reform, public investment, and existing frameworks. This shift creates immediate compliance implications for Canadian businesses operating across privacy law, human rights legislation, and sector-specific regulation, while positioning the country between the EU's prescriptive approach and the U.S.'s deregulatory stance.

Saskatchewan's new Data Centre Framework and Canada's Responsible Data Centre Development Principles establish comprehensive guidelines for data centre development, emphasizing Canadian ownership, data sovereignty, and bring-your-own-power requirements. How will these frameworks shape the future of data centre investments and operations across Canadian provinces, and what challenges remain in implementing these high-level policy priorities?

Effective September 8, 2026, Canada implemented retaliatory tariffs on certain U.S. goods in response to the initial 50% tariffs imposed by the US under Section 338 of the Tariff Act of 1930. To operationalize these measures, the Canada Border Services Agency (CBSA) issued Customs Notice 26-23, establishing binding administrative rules on how the surtax will be applied, calculated, and collected.

With Labour Day now behind us, Parliament Hill is gearing up for its September 21 return. Canada’s counter-tariffs on nearly $28 billion in American goods are now in force, and the United States has already escalated in response: President Trump has signed measures to ban certain Canadian alcohol, dairy-related products, molasses, non-alcoholic beer, motorcycles and mopeds from entering the U.S. market as of September 29, while modifying the list of Canadian goods subject to 50% tariffs effective September 15 and directing action to remove Canadian-origin products from U.S. government procurement schedules.

Under Order in Council 1358-2026, the Québec government authorizes, from September 7, 2026 to January 31, 2027, the Centre d'acquisitions gouvernementales (the “CAG”) to depart from the general principle that public calls for tenders must be open and without discrimination to foreign suppliers from jurisdictions bound by an intergovernmental agreement with Québec.

Canada has announced the imposition of new tariffs on US goods beginning on September 8, 2026. Canada’s retaliatory tariffs were introduced in response to US tariffs on Canadian goods that entered into force on August 22, 2026.

A regulatory shift now under consideration in Ontario could reshape how the province’s medical aesthetic clinics operate. The proposal, which would change how nurses are authorized to administer medical aesthetic services, invites a broader look at how Ontario currently regulates cosmetic injections and how the proposed changes would align the province more closely with the regulatory frameworks already in place elsewhere in Canada. While these procedures are often marketed as routine “spa” services, they remain medical acts that involve prescription products and carry clinical risks.

On July 29, 2026, Health Canada announced that it had obtained a permanent injunction against a Québec-based company in connection with the sale of unauthorized injectable peptides in Canada. The announcement reflects Health Canada’s continued focus on peptide products and serves as a reminder that injectable peptides intended for human use are regulated as prescription drugs and are subject to Canada's drug regulatory framework.

The growth of the gig economy has fundamentally changed how many organizations deliver services and engage workers. From rideshare platforms and delivery services to consultants, franchise operators and other independent contractors, organizations are increasingly relying on non-traditional working relationships that fall outside the conventional employer-employee model.

Unmanned Aerial Systems (UAS), commonly referred to as drones, are increasingly used in Canada for commercial purposes such as infrastructure inspection, real estate photography, agriculture, filmmaking, mapping and resource exploration. Their advantages are clear: they are flexible, relatively inexpensive and capable of collecting information from angles and locations that would otherwise be difficult to access.

The Office of the Superintendent of Financial Institutions (OSFI) published its third quarterly release of the year on September 10, 2026, noting that the targeted adjustments made to its guidance were made with a view to supporting a resilient and competitive Canadian financial system.

On June 4, 2026, the Government of Canada released Canada’s National Artificial Intelligence Strategy: AI for All, a five-year plan to accelerate AI adoption, strengthen domestic AI capacity and build public trust in AI systems. With the release of the AI for All strategy, the Government does not announce a new omnibus AI statute. Instead, it sets out a more targeted policy framework, informed by industry and stakeholder feedback, that organizes federal AI policy around six pillars: