On February 10, 2026, ICLMG’s National Coordinator testified at the Standing Senate Committee on Social Affairs, Science and Technology (SOCI) for their study of the rights-violating and xenophobic Bill C-12, the Strengthening Canada’s Immigration System and Borders Act.

Watch his 5-minute intervention above or read the transcript of his remarks below.

Read our full briefs to the SOCI committee here or the SECD committee here.

And please take action and share widely. Thank you!

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TRANSCRIPT

Good morning and thank you for this opportunity to share concerns and feedback regarding Bill
C-12 on behalf of the International Civil Liberties Monitoring Group, a coalition of 44 Canadian
civil society organizations that works to defend civil liberties in the context of national security
and counter-terrorism measures.

Since the introduction of Bill C-12, and of Bill C-2 before that, we have expressed our urgent concern that this legislation poses a danger to the rights and livelihoods of migrants and refugees in Canada, as well as the privacy rights of nearly all people across the country.

As a coalition focused on national security and civil liberties, it may not be apparent why we would speak out over legislation relating to changes in the immigration and refugee system. In our work, though, we have seen time and again how migrants and refugees are used as scapegoats for challenges we face in society, and how quickly and easily they are unjustly framed as national security or public safety threats. We cannot forget the roots of this legislation: it is the follow-up to $1.3 billion announced in December 2024 to increase surveillance, law enforcement and other security measures at our border as a response to accusations from the United States that Canada poses a severe security threat to our southern neighbor, despite clear evidence that this simply is not true.

It is unacceptable that Canada would erode fundamental rights or dismantle systems meant to welcome newcomers and protect those fleeing injustice because of trumped up pressure and manufactured emergencies.

Given all of this, we believe Bill C-12 is fundamentally flawed, and must be withdrawn. Barring that, there are specific areas of the bill that we believe deserve attention.

I’m glad to be on this panel with so many esteemed colleagues who will be able to speak to various aspects of Bill C-12. For my part, I would like to focus on two crucial areas.

First, we are opposed the changes in part 7 of Bill C-12, that would grant Cabinet the extraordinary ability to issue orders to, among other things, suspend or terminate applications for various forms of visas or other immigration documents, as well as to cancel, vary or suspend existing immigration documents, including temporary visas and permanent residency cards, based on the vague notion of “Public Interest.”

Such broad powers, with no safeguards apart from public reporting, are ripe for abuse, particularly given the lack of a specific definition of “public interest.” Instead, the bill puts forward a non-exhaustive list of areas that fall under the “public interest”, including administrative errors, fraud, public health, public safety or national security. Even if we were to believe that the government would limit itself to acting in these areas, they are so broad as to be able to capture nearly any situation. “Public Safety” and “National Security” alone can, and have been, used by governments to excuse policies that target populations from specific countries, or of specific cultural or ethnic background, or that espouse particular political or religious beliefs.

Being able to mass cancel the documents of individuals already in the country raises horrendous possibilities of mass deportations based on tenuous allegations of “public safety,” all under the guise of protecting the “public interest.”

We may be told that the current government would not use these powers in this manner; that may well be true. But this cannot be guaranteed for future governments.

It is difficult to see how such powers can be saved through amendments. We would recommend that Part 7 be struck from Bill C-12.

Second, we are also critical of provisions in Part 5 that would expand the ability of Immigration, Refugees and Citizenship Canada to share private information across federal, provincial and territorial governments, as well as with foreign entities. These changes would have a significant impact on the privacy of all people in Canada, regardless of status. For migrants and refugees, the powers could inhibit their ability to access critical services without fear or harm, as well as pose serious risks for those fleeing persecution by foreign states. Permanent residents and Canadian citizens could also see their privacy impacted, including the sharing of personal details collected in residency or passport applications.

While the categories of what information can be shared may appear narrow, it could in fact be quite revealing, and could also be used in ways that would significantly impact an individual’s well-being and security far beyond the immigration and refugee system. This becomes especially true if information about changes to status, identity, or the refusal, termination or revocation of documents are shared with law enforcement or other provincial or municipal authorities, or foreign entities.

Moreover, once information is shared widely, it becomes nearly impossible to control its flow.

While Canadian laws may impose restrictions domestically, this is not the case once information is shared internationally. While officials have claimed C-12 will not permit foreign information sharing, we disagree, and I would be happy to share further details during the question and answer session.

Given all of this, and the fact that information disclosure powers already exist at the federal level, we would also argue that Part 5 should simply be removed.

Thank you for your time and I look forward to your questions.

On February 2nd, 2026, the International Civil Liberties Monitoring Group sent the following comments to the federal government in the context of their 30-day consultation on their proposed Regulations for the Foreign Influence Transparency and Accountability Act (which was part of Bill C-70, the Combatting Foreign Interference Act, which was rushed through Parliament in May and June 2024):

Concerns

The Foreign Influence Transparency and Accountability Regulations as currently drafted fail to clarify some key aspects of the Foreign Influence Transparency Registry that were raised during the legislative process and that are necessary for ensuring clarity and specificity regarding the conditions under which individuals and organizations must register.

In particular, there is concern regarding the term “foreign principal” and what constitutes an “arrangement,” as well as the lack of inclusion of any clear exceptions to the requirement to register beyond those in the Act, which are currently insufficient.

These concerns are acknowledged in the “Consultation” subsection under “Regulatory Development”, where it states that “Lastly, civil society organizations and diaspora groups had questions about registration requirements for individuals linked to foreign-funded institutions or media outlets. Clarification on this issue will be shared through future outreach materials.”

However, future “outreach” will not adequately serve the purpose of providing the certainty necessary for individuals and organizations around whether their activities require registration with the foreign influence transparency registry that can only be achieved in either regulations or in the law. Moreover, during consultation sessions and engagement around the Combatting Foreign Interference Act, there were assurances given that certain areas would be further defined under regulation, including what constitutes a foreign principal, further specifics around what constitutes an arrangement with foreign principals, and entities or kinds of arrangements that would be excluded from the need to register.

Without further clarifications or carve-outs, Canadian organizations that work in association with, for example, the United Nations, NATO, the World Health Organization, the International Labour Organization, La Francophonie or any other host of organizations whose members are States may face a requirement to register their activities with the foreign influence transparency registry. Canadian individuals and organizations who work in association with State controlled/funded academic institutions or media could also be required to register their activities. For example, countries, including France, Germany, Mexico, Australia, have extensive and robust publicly funded university systems. Others, like the UK, France and Australia, also feature publicly funded media.

Because of the lack of clear definition of what constitutes “working in association with” under the definition of an “arrangement” in the Foreign Influence Transparency and Accountability Act, there is no clarity around what consists of an “association.” As the Canadian Civil Liberties Association pointed out in their brief on Bill C-70, there is no requirement for an association to consist of a subordinate relationship between the Canadian and foreign entity, where the foreign entity exerted a degree of control over the Canadian entity. Would, therefore, simply being in contact with a multilateral organization, an academic at a foreign university or with a journalist at a publicly funded broadcaster about an issue that raises public policy concerns, require registration? The lack of clarity in both the law, and in regulation, leaves this open to misinterpretation and a quashing of Canadian civil society engagement in multi-lateral platforms and discussions.

Given the significance of the administrative monetary penalties proposed in the regulations, this could result in a high degree of over-compliance and will also require the expenditure of valuable time and limited resources and capacity. It would also result in a large number of international cooperation activities that are in no way under “foreign influence” being labeled as such, and therefore stigmatizing work that is otherwise to be encouraged and supported.

This would also have an impact on freedom of expression, given that organizations that work with international partners who fall under the definition in the Act may refrain from speaking out on issues that they would normally engage on, because of the concern that they would now need to register.

Finally,  the ICLMG remains concerned that the registry could be used to surveil international engagement instead of fulfilling its declared purpose. The information organizations will be required to submit would be a trove of data that government agencies would never otherwise be privy to. While on its own innocuous, it could be used to map legitimate activities for other national security or foreign affairs purposes that are at best case unrelated, but could also be either detrimental, harmful or at odds with the work being carried out. For example, information regarding international human rights work could reveal to government officials partnerships that would otherwise remain confidential to protect identities. While this may not be publicly listed in the registry, it could be accessed by national security agencies under other legislation. This information could be This information could be abused for political reasons, or used in ways that place the work or people’s lives in jeopardy.

Recommendations

It is imperative that regulations address these concerns before any future registry is established. We would encourage the government to re-open consultations with civil society stakeholders in advance of adopting these regulations. We would also recommend that the government look to other countries to examine what kind of carve outs and exceptions currently exist that could be integrated into this regime. This includes, for examples, carve outs for humanitarian aid and charities, for scientific, academic and religious pursuits, for news media, among others, in US, Australian and UK regimes.

The People’s Consultation on AI, launched on January 21, 2026, is a collaborative civil society initiative created in response to the federal government’s failure to provide a meaningful consultation process during the development of a national AI strategy in October 2025.

In 2025, the government hastily assembled a task force to develop its AI national strategy. It was heavily skewed towards industry with very few participants able to speak to the broader ethical, social and political implications of the technology.

An accompanying public consultation allowed just 30 days for feedback, impeding those most impacted by AI from effectively participating. The government’s consultation survey questions prioritized economic benefits over AI’s many negative impacts and responses are now being assessed by AI rather than public officials.

These and other shortcomings were detailed in an open letter signed by over 160 civil society organizations and experts in October 2025, protesting the government’s “national sprint” on AI and documenting the many negative impacts that are already occurring as AI technologies become embedded in every aspect of Canadian society.

The People’s Consultation on AI offers a meaningful alternative. Beginning today, public interest groups, academics, impacted communities, and people across Canada have a meaningful opportunity to have their say on whether–and how–AI should be adopted and governed in Canada.

Designed for broad participation, the People’s Consultation on AI welcomes everything from the results of neighbourhood discussions about AI’s everyday impacts to in-depth expert analyses. The consultation website provides resources on current implications of AI alongside general guidance and community facilitation tools to help people craft submissions collaboratively.

Submissions will be published on the consultation website, shared with the federal government, and support civil society efforts to build a comprehensive response to the threats posed by AI.

The People’s Consultation on AI will be accepting submissions until March 15, 2026.

Participate in the consultation here:

English: https://www.peoplesaiconsultation.ca/

Français : https://www.consultationpopulairesurlia.ca/

Selected Quotes: Quotes represent the views of the individuals or organizations quoted

“Law enforcement and security agencies are increasingly relying on AI tools to supercharge surveillance, in an attempt to assess situations in real time and to even claim to predict future behaviour. Too often these AI tools are biased and their continued unregulated adoption will continue to have devastating impacts on people. It is imperative that communities affected by these technologies have the opportunity to weigh in on their impacts and possible safeguards – and that the Canadian government listen to what they have to say.” – Tim McSorley, National Coordinator, International Civil Liberties Monitoring Group

“The Canadian government is pushing AI hard as a boon to our economy. It seeks our trust but fails to make a good case for AI’s benefits. It avoids addressing the many serious pitfalls, especially of generative AI, and makes only token efforts to engage Canadians broadly in this important policy debate. The People’s Consultation on AI, in providing Canadians with a more open, inclusive and informed basis for expressing their views, offers a powerful corrective. Government should heed the coming results.” – Andrew Clement, Professor emeritus, University of Toronto

“The collateral damage around the intoxicated rush to embrace AI can be measured in laid-off workers, psyop campaigns in the service of corrupt oligarchs and autocrats, women and vulnerable minorities bullied into silence by swarms of deep fakes, and teen suicides. It is entirely unacceptable to allow tech platforms to experiment on billions of people for private gain with no meaningful restraints. We urgently need mandated transparency requirements, independent auditing of AI platforms, and stronger privacy and consumer protection laws.”
– Ronald J. Deibert, O.C., O.O., Professor of Political Science and Director of the CitizenLab, The Munk School, University of Toronto

“The government’s rush to automate services with unregulated AI could cement systemic biases, disproportionately harming vulnerable Canadians. Refugees and immigrants face the gravest risk of being left behind, potentially thrust into deeper precarity by algorithmic systems.” – Debbie Douglas, Executive Director, OCASI – Ontario Council of Agencies Serving Immigrants

“We hope that this consultation exercise will demonstrate that social innovation in AI is also compatible with values of inclusion and social justice. Including citizens’ perspectives and, more broadly, civil society in AI governance is essential to ensure that we develop in Canada AI systems that meet the needs of the population as a whole and in all its diversity.” – Karine Gentelet, Full Professor, Université du Québec en Outaouais & scientific director Collaboration with Civil Society Obvia

“Canada cannot claim AI leadership while sidelining the communities already being harmed. From automated discrimination to technology facilitated gender based violence, AI is amplifying structural harm, and those most affected must be central to shaping Canada’s AI future.”
– Meseret Haileyesus, CEO Canadian Center for Women’s Empowerment (CCFWE)

“We need workers and the public to have a real say in shaping a public vision for AI in Canada. It’s the only way to make sure AI serves workers and ordinary folks, not just big tech corporations. CUPE is calling for strong laws and regulations to protect workers, the public and the environment.” – Mark Hancock, CUPE National President

“In its sprint to make Canada an AI leader, our government is putting business interests ahead of dealing with its impact on human rights, the environment and democratic integrity. Yet public opinion polling is extremely clear: Canadians are demanding an AI strategy that addresses these negative impacts head on, not one that treats them as an afterthought.” – Matt Hatfield, Executive Director, OpenMedia

“Artificial intelligence has had wide-reaching effects on society and will continue to for the foreseeable future. It is imperative that we mitigate the potential harms of AI on the Canadian people and its democratic institutions.” – Khasir Hean, Co-Organizer, Technologists for Democracy

“AI is being adopted with a concerning disregard for the negative impacts it is having on our lives–impacts that fall most heavily on groups that are already precarious. As AI reshapes how we work, how we learn, how we interact with each other, and how we are policed by the state, it is imperative that Canada adopt an informed strategy for dealing with this technology.” – Tamir Israel, Director, Privacy, Surveillance & Technology Program, Canadian Civil Liberties Association

“Proponents of novel technologies celebrate speed in embracing change without regard to consequences, but this is a catastrophic approach to legislation. The government puts our fundamental rights at risk — including the equality and privacy rights that are essential to a free and democratic society — when they allow the development of AI regulation to be rushed or dominated by industry interests.” – Aislin Jackson, Policy Staff Counsel, BC Civil Liberties Association

“The federal government’s approach to a national AI “strategy” has resembled a parody of AI boosterism, with their purported consultation a thin veneer for manufacturing consent where they know there is none. It is a slap in the face to every historically marginalized community and vulnerable person who has already been harmed by the carelessness and arrogance of robber tech barons prioritizing profits over people and ego over ethics. If we have learned one thing repeatedly from the cascading and discriminatory harms of so many cycles of tech hype—whether big data, social media, algorithmic decision-making, or genAI—it’s that those hardest hit often see the future first, but are the last to be heard. This collective initiative is an attempt to steer Canada away from making that profound mistake yet again.” – Cynthia Khoo, Senior Fellow, Citizen Lab; technology & human rights lawyer

“Reckless adoption of AI systems is already undermining substantive equality in our daily lives. We need regulatory controls that centre human rights and substantive equality to mitigate the profound harms of this technology, but the government is developing a national strategy on AI without hearing from those who will be the most impacted.” – Rosel Kim, Senior Staff Lawyer, Women’s Legal Education and Action Fund (LEAF)

“AI’s real existential threat is to democracy itself. The government needs to take public participation in AI governance seriously or else lose its legitimacy to govern all together. The push to adopt AI above all risk ignore the countless voices asking for AI that works for people not profits” – Fenwick McKelvey, Associate Professor, Concordia University

“Buying into AI hype is not going to help us build a better future. We can build a better and uniquely Canadian path by taking the very real concerns of everyone in Canada about AI seriously, engaging in meaningful consultations, ensuring rights of refusal and developing strong enforceable protections that prioritize the well-being of people and the environment over the interests of the big tech companies who are causing so much harm.” – Joanna Redden, Co-Director Starling Centre

“Students’ learning, development, and growth is being dictated by a handful of trend-obsessed and profit-driven technology companies whose interest is their bottom line rather than student welfare. Growing evidence of the negative impacts of generative AI on students’ critical thinking skills and their social, cultural, and psychological wellbeing should be raising huge alarms against this uncritical and non-consensual integration. Meanwhile, the government invests in generative AI which undermines educators’ labour and working conditions, wasting resources better used to address real issues in education. The People’s Consultation on AI is a vital step in pushing back and ensuring the future of Canadian education centres the real needs of educators and students.” – sava saheli singh, Assistant Professor of Digital Futures in Education, York University

“AI policy cannot be left to the industries profiting from it. BC Policy Solutions endorses the People’s Consultation because we need an AI governance framework grounded in economic justice—one that protects workers and the environment, reclaims public data infrastructure and ensures AI serves collective social needs rather than just a private oligopoly.” – Véronique Sioufi, Racial Equity Researcher, BC Policy Solutions

“The concerns raised by civil society and by communities most affected by AI, in Canada and beyond, must be listened to and seriously considered by the government. The infrastructure supporting AI in Canada—particularly as part of a broader push toward digital sovereignty, including data and data centers—carries profound ethical, financial, social, and environmental consequences that warrant public debate. In the context of the climate crisis, AI poses significant environmental challenges, driven by large-scale mineral extraction and the substantial water and energy demands of data center operations. Claims of Canadian AI sovereignty cannot be credible without democratic participation by civil society in decisions that shape this technology, including saying no.” – Sophie Toupin, Assistant Professor, Université Laval