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On November 4, 2025, the federal government tabled Bill C-15, an Act to implement certain provisions of Budget 2025. Among its proposed amendments to the Personal Information Protection and Electronic Documents Act (PIPEDA) is the introduction of a data mobility framework, a significant development aimed at giving Canadians greater control over their personal information. While the language is preliminary, it signals the federal government's intention to create a legal right for individuals to transfer their data between organizations in a secure and standardized way.
What is data mobility?
Data mobility, sometimes referred to as data portability, is the ability for individuals to request that their personal information be transferred from one organization to another in a usable format. This concept, previously contemplated in Canada's proposed Consumer Privacy Protection Act, which was wiped from the Order Paper with the prorogation of Parliament at the beginning of 2025, breaks down barriers that lock consumers into specific platforms. In practice, this means individuals could seamlessly move their financial, health, or other personal data between providers without starting from scratch.
The proposed amendment to PIPEDA contemplates various "data mobility frameworks" that will be specified in future regulations and are likely to be rolled out on an industry-by-industry basis. Bill C-15 also introduced an updated version of the Consumer-Driven Banking Act (i.e., open banking), which will be the first iteration of such a framework that will apply to consumer financial data.
Quebec's Law 25
Quebec was the first Canadian jurisdiction to introduce a right to data portability under Law 25, which came into force in September 2024. Quebec's regime requires organizations to provide personal information in a structured, commonly used format upon request, enabling individuals to transfer their data to another entity. Data portability rights do not currently exist outside Quebec, making the federal proposal under Bill C-15 a potential game-changer for national consistency.
What's next?
It is important to note that Bill C-15 provides only the foundation of the framework. The proposed provisions defer most of the substance to future regulations, which will define critical elements such as technical standards, security safeguards, interoperability requirements, and exceptions for proprietary or confidential commercial information. Until these regulations are enacted, the practical application of data mobility remains uncertain. By laying the groundwork for economy-wide data portability, the government is signaling its commitment to consumer empowerment and digital innovation.
Organizations should consider starting to prepare for a future where data portability becomes a standard expectation. This means assessing current data management practices, anticipating interoperability requirements, and monitoring regulatory developments closely. While the timeline for implementation is unclear, early planning will help businesses adapt quickly when detailed regulations arrive.
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