Thank you very much to the committee for inviting me today to discuss how to protect Canada's elections.
My name is Chris Tenove. I'm a political scientist and the assistant director of the Centre for the Study of Democratic Institutions at the University of British Columbia, where I research digital media, democracy and tech regulation.
Today, I'm going to focus on challenges posed by artificial intelligence and social media. My general observation is that Bill C-25 resembles a security patch for electoral software. It fixes some important weaknesses and should be promptly enacted, possibly with some changes, but a more substantial update to the operating system is still needed.
I will flag gaps that remain regarding four issues. These are AI-generated content, false claims about electoral processes, chatbot errors and bias, and AI agents.
First, generative AI can create synthetic media that impersonates individuals or official publications. That's a real risk. The amendments to sections 480.1 and 481 are appropriate.
The Chief Electoral Officer and others have suggested that all synthetic content in electoral communications should be labelled as well. That may be helpful, but I don't think it's essential at this time. Enforcement would be difficult, and the core problem is misleading content, not necessarily that it is AI-generated. However, the deceptive use of unlabelled synthetic content could be a factor when determining whether an actor is being intentionally misleading.
Second, generative AI and social media platforms make it easier to spread false claims about electoral processes. Bill C-25 appropriately clarifies and expands prohibitions on such claims. I am sympathetic to the Chief Electoral Officer's proposal to add “intent to delegitimize elections” as a prohibited purpose, though that language may need to be narrowed. Importantly, neither the Chief Electoral Officer nor the commissioner of Canada elections currently has the authority to require prompt removal of prohibited impersonation or false claims about elections processes. The B.C. Elections Act gives Elections BC exactly this power, and I propose that equivalent authority be given to the commissioner of Canada elections.
Third, citizens increasingly get civic information from general-use chatbots like ChatGPT, AI companions and AI search tools. However, these models sometimes give incorrect information regarding elections. For instance, Demos, a UK-based think tank, tested several AI services during the Scottish parliamentary election and found that 34% of responses contained factual errors, including wrong dates and hallucinated candidates. Such errors could harm election participation.
Beyond errors, AI services may deliver biased outputs. For instance, in 2025, the Dutch data protection authority warned voters not to use chatbots for voting advice after finding that popular chatbots vastly over-recommended certain parties. Risks of bias become more acute if AI models face data-poisoning attacks or are designed to advance a bias, perhaps in alignment with business models. It's worth noting that OpenAI has begun running ads on ChatGPT in some markets.
Election laws should ensure that chatbots and other AI services document and report all political ad spending, and Bill C-25 should close any gaps. Moreover, just as the Elections Act was amended to improve transparency for social media advertising through ad registries, we need new mechanisms to bring transparency to AI services to address harmfully inaccurate or manipulated information.
Fourth, AI agents can do more than create content. They can plan, take autonomous action, coordinate across platforms, and raise and spend money. Responsible actors will build in human oversight and malicious ones will not. I suggest that you confirm that there is language that holds responsible those who use AI agents for prohibited activities and requires parties and other actors to ensure that there is a responsible individual organization behind all contributions.
Finally, election law alone cannot detect, stop and secure accountability for malicious AI agent activity and other threats I've mentioned. It needs to be supported by broader AI and platform regulation in order to act on illegal activity and impose obligations to mitigate systemic harms. We also need stronger protections for citizens' data that's held by political parties.
These are all parts of the updated operating system that I think Canadian democracy needs, in addition to the near-term patch that Bill C-25 provides.
Thank you, and I look forward to your questions.