Bill 194 Is Now Law in Ontario: What You Need to Know

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    Ontario has officially passed Bill 194, the Strengthening Cyber Security and Building Trust in the Public Sector Act, 2024. This landmark legislation is now in force and sets new standards for cybersecurity, artificial intelligence (AI) oversight, and data privacy across public sector organizations.

    Key Milestones

    • Passed into law: November 25, 2024 (Royal Assent)
    • Cybersecurity & AI rules in effect: January 29, 2025
    • Privacy reforms in effect: July 1, 2025

    What the Law Covers

    Bill 194 introduces sweeping changes aimed at strengthening digital trust and accountability within Ontario’s public sector. The legislation:

    • Raises cybersecurity requirements for ministries, municipalities, healthcare institutions, and other public organizations.
    • Creates a framework for responsible AI use in public services, with future regulations expected to guide transparency, fairness, and risk management.
    • Enhances privacy laws by requiring mandatory privacy impact assessments (PIAs), breach reporting for incidents that pose a “real risk of significant harm,” and stronger powers for the Information and Privacy Commissioner (IPC).

    Who Is Affected?

    This legislation directly impacts:

    • Government ministries and agencies
    • Municipalities and school boards
    • Hospitals, universities, and other public institutions
    • Private vendors and SaaS providers working with public sector clients
    • Regulatory bodies
    • Or any org in the “broader public sector” (BPS)

    If your organization works with or supports these sectors, you may be expected to align with new security, privacy, and AI governance expectations.

    What You Should Do Next

    Organizations should take steps to:

    • Review and strengthen cybersecurity practices
    • Prepare for AI accountability measures
    • Ensure privacy policies and incident response plans meet new standards

    Frameworks such as NIST Cybersecurity Framework (CSF) 2.0, ISO 27001, ISO 42001 (for AI governance), and NIST AI Risk Management Framework (RMF) 1.0 provide guidance that helps organizations maintain compliance, manage risk, and stay ahead of emerging threats.

    Bill 194 marks a turning point in how Ontario’s public sector—and those who support it—approach technology, privacy, and public trust. Now is the time to take action.

    If you need support preparing for compliance, our team can help you understand your obligations and build a roadmap that works for your organization.

    Bill 194 marks a turning point in how Ontario’s public sector—and those who support it—approach technology, privacy, and public trust.

    Now is the time to take action.

    If you need support preparing for compliance, our team can help you understand your obligations and build a roadmap that works for your organization.

    Schedule a consultation