Comparing the Safe Social Media Act to CIPPIC’s Previous Positions
Jun 25, 2026

The Canadian government has introduced Bill C-34, the Safe Social Media Act, the latest attempt to regulate online harms after earlier bills died on the Order Paper. C-34 is more ambitious than its predecessors. It would: (1) set a minimum age of 16 for social media accounts on services the government designates, backed by mandated age checks; (2) create online harms duties for platforms; (3) require age checks on sites that host pornography; (4) set up a regulatory scheme for AI chatbots; and (5) establish a new federal regulator, the Digital Safety Commission of Canada (the Commission). Many of these measures echo earlier Canadian bills or laws adopted abroad.
There’s a lot to say about C-34.We’ll start by asking how it measures up against the recommendations CIPPIC advanced in its brief and open letter, both later picked up by TVO and National Post. On some points, the bill delivers. On others, it diverges from CIPPIC’s recommendations, or acknowledges the concern without fully resolving it. The key question is whether the bill achieves the underlying objective each recommendation was meant to serve.
CIPPIC previously urged the government to take the following steps. In this post, we assess Bill C-34 against each of them.
✓ 1. Engage in significant study and consultation with experts and stakeholders in Canada and beyond.
We need a comprehensive regulatory strategy that aligns with efforts in like-minded countries, and that respects the global nature of the internet.
→ The government spent years consulting on online-harms policy. However, several of the bill’s measures don’t obviously trace back to that work, the clearest being the new minimum-age rules for social media (ss. 26-29). The government should identify the consultation those provisions rest on, and whether it heard from children and young people who have more at stake here than almost anyone.
✗ 2. Legislate holistically rather than in isolation.
Rather than focusing just on online harms, the government should tackle platform regulation holistically - as happened in the European Union with the introduction of the Digital Services Act and the Digital Markets Act in tandem. Online harms cannot be legislated in isolation. There is a growing consensus that platform amplification of harmful material is a symptom of business models premised on surveillance capitalism and the concentration of market power by technology companies.
→ C-34 stays narrow. It imposes duties on social media and chatbot services but leaves untouched the underlying incentives that drive harmful content toward users: recommendation systems, surveillance-based advertising, and concentrated market power. A law that treats the symptoms and ignores the causes can only go so far.
✗ 3. Do not take actions that could jeopardize claims that Canada is a global leader in human rights.
Ensure actions increase human rights rather than decrease them.
→ The bill’s age assurance duties (ss. 20-29) come with privacy safeguards: operators can collect personal information only to check age, must protect it, and must destroy it once the check is complete (ss. 22(2), 27(2)). The Commission also must consult the Privacy Commissioner before it issues age-assurance guidelines (s. 122(2)). The question is whether those safeguards will survive contact with commercial incentives. Faced with heavy penalties, platforms will have every reason to choose the method easiest to defend as “effective” age-verification. In practice, that will mean government ID checks and facial scans rather than less intrusive alternatives. The likely result will be large-scale collection of sensitive identity data by private companies, creating privacy and security risks well beyond anything the bill appears to contemplate. We already show ID to buy alcohol, but handing identity documents or facial data to online platforms introduces a different order of risk.
✗ 4. As a first step, acknowledge how business models premised on surveillance capitalism contribute to online harms.
Legislate from this basis.
→ The bill doesn’t touch this. Surveillance capitalism goes unnamed, though the same concern runs through recommendations 2 and 3. The bill targets harmful content hosted on platforms but leaves the data-harvesting model that drives it untouched.
