Understanding Bill C-25: What It Means for Political Advertising in Canada
As part of ongoing efforts to strengthen Canada’s federal elections framework, Bill C-25 was introduced and is currently under consideration. While the bill does not directly amend existing requirements for online political advertising transparency, it introduces measures that may be relevant to participants in the digital advertising ecosystem.
This post provides a high-level overview of the bill and highlights areas that advertising professionals, agencies, and ad tech providers may wish to be aware of.
No Changes to Online Political Ad Transparency Requirements
At this time, Bill C-25 does not modify the provisions of the Canada Elections Act related to online political advertising registries or transparency requirements. As such, existing expectations regarding ad disclosures and platform obligations remain unchanged.
Participants in the DAAC Political Ads Program should continue to follow the current Principles, including requirements related to notice and record-keeping for regulated political advertising.
New and Expanded Provisions Related to Foreign Influence
Bill C-25 introduces and expands provisions aimed at limiting foreign influence in Canadian elections. These include restrictions related to:
The sale of advertising space for election or partisan advertising to certain foreign entities
The use of foreign funds, property, or services in relation to regulated political advertising activities
While these provisions are not directed at advertising technology itself, they focus on the source and control of political advertising activities.
What This May Mean for the Advertising Ecosystem
For agencies, platforms, and ad tech providers, these changes may be relevant in situations where political advertising involves cross-border elements.
For example, where advertising tools, platforms, or services are provided by entities based outside of Canada, it may be important to consider:
Who is directing and controlling the advertising campaign
Whether the advertiser is a Canadian entity eligible to engage in regulated political advertising
Whether any aspect of the arrangement could be interpreted as a contribution or involvement from a foreign entity
In general, the use of third-party advertising technology does not, in itself, determine compliance. Responsibility for complying with the Canada Elections Act remains with the political advertiser or regulated third party.
Additional Privacy Considerations for Political Parties
The bill also introduces enhanced privacy-related expectations for federal political parties, including requirements related to safeguards, transparency, and the handling of personal information.
While these provisions are not specific to advertising practices, they may be relevant to how political actors approach data use and audience engagement over time.
Looking Ahead
As Bill C-25 progresses through the legislative process, further guidance may be issued by Elections Canada or other relevant authorities to clarify how these provisions should be interpreted in practice.
The DAAC will continue to monitor developments and share updates where appropriate.
In the meantime, participants may wish to remain mindful of how political advertising campaigns are structured, particularly where multiple parties, jurisdictions, or service providers are involved.