No federal or Quebec statute we checked speaks to AI chat or voice agents directly, so the answer comes from privacy, competition and Quebec rules. Here is what each one requires, and the practice that follows.
Does any Canadian law require a chatbot to say it is an AI?
In the federal and Quebec laws we checked for this guide, we found no statute that says so outright. A federal government page on the proposed Artificial Intelligence and Data Act, archived in December 2025, states that Canada has no regulatory framework specific to AI (ISED).
That does not make silence safe. Privacy commissioners expect disclosure, the Competition Act covers misleading representations, and Quebec’s Law 25 sets rules for automated decisions and profiling.
What do privacy commissioners expect?
That people know they are dealing with AI. In principles published in December 2023 by the federal privacy commissioner and its provincial and territorial counterparts, including Quebec’s Commission d’accès à l’information (CAI), organizations using a public-facing generative AI tool should make sure people interacting with it know it is a generative AI tool (OPC principles).
The commissioners phrase these as recommendations, but say many of them will be required by privacy law. They also flag, as a potential no-go zone, the use of conversational bots to deliberately nudge people into revealing personal information, especially sensitive information, that they would not otherwise share.
For a leasing agent, that means saying it is an AI up front and asking only what the unit and the showing require.
Could a bot that poses as a person mislead under the Competition Act?
It could. Section 74.01 makes it reviewable conduct to make a representation to the public, to promote a product or any business interest, that is false or misleading in a material respect (Competition Act s. 74.01).
The section does not mention AI. But an agent that tells a renter it is a person is making a representation while promoting your rentals, so the safe course is simple: never claim or imply to be human.
What does Quebec’s Law 25 add?
Two rules that matter for AI in leasing, both in force since September 22, 2023 (Québec Official Publisher, 2021, c. 25).
Automated decisions (s. 12.1). If you use personal information to make a decision based exclusively on automated processing, you must tell the person no later than when you tell them of the decision. On request, you must also tell them the information used, the reasons and the principal factors and parameters, and their right to have the information corrected. They must be able to submit observations to a staff member who can review the decision (CAI, in French).
Profiling (s. 8.1). If you collect personal information with technology that can identify, locate or profile someone, you must first tell them about the technology and the means to activate those functions. Profiling includes assessing a person’s economic situation, preferences, interests or behaviour, and the CAI says these functions cannot be activated by default (CAI, in French).
In practice, keep a person in every decision on a Quebec application, and do not turn on AI scoring or ranking of Quebec renters by default.
Do you have to announce that calls are recorded?
Yes, under privacy law. The Criminal Code’s interception offence does not apply to someone who has the consent of the person who made the call or of the person it was meant for (Criminal Code s. 184). The Office of the Privacy Commissioner of Canada (OPC) still says an organization recording customer calls must tell the caller, state the purpose clearly and ask for consent (OPC).
If the caller continues knowing the call is recorded and why, consent is implied. If they object, offer another way to deal with you, such as in person, in writing or online, and do not cite quality assurance if the recording will also serve marketing or profiling. The guidance covers calls you make as well as calls you receive.
That guidance interprets PIPEDA, the federal law. Alberta, British Columbia and Quebec have their own private sector laws, which generally apply instead of PIPEDA to activity within the province (OPC), and in Quebec you must tell people at collection the purposes and means of collecting their information (s. 8) (Québec Official Publisher).
What should your AI leasing agent do?
Disclose early, never pose as a person, and hand off. These habits follow from the rules above:
- Say it is an AI in the first sentence of every call and the first message of every thread, and confirm it whenever asked.
- Never claim or imply to be a person.
- Ask only what the unit and the showing require.
- Announce recording and its purpose at the start of calls, and offer another channel to anyone who objects.
- Offer a person on request, and keep your team in charge of decisions on applications.
The rules at a glance
| Rule | What it requires | Source |
|---|---|---|
| AI-specific statute | None found in the federal and Quebec sources we checked | ISED |
| Privacy commissioners’ principles (2023) | Public-facing generative AI should make clear it is AI; bots that nudge people to reveal personal information are a potential no-go zone | OPC and provincial and territorial commissioners |
| Competition Act s. 74.01 | No representation to the public that is false or misleading in a material respect | Justice Laws |
| Quebec Law 25, s. 12.1 | Automated-only decisions: notice, explanation on request, review by a staff member | Québec Official Publisher; CAI |
| Quebec Law 25, s. 8.1 | Technology that identifies, locates or profiles: inform first; not on by default | Québec Official Publisher; CAI |
| Call recording | Tell the caller, give the purpose, ask consent, offer alternatives | OPC; Criminal Code s. 184 |