Is your organisation ready for Bill C-26?

Bill C-26 is now Bill C-8, and the Critical Cyber Systems Protection Act it enacts is law but not yet in force as of 2026-08-27. No operators are designated. If you run or supply a federally regulated system in one of the six sectors Schedule 1 names, this check gives you an honest readiness tier before the duties attach.

  • 6 questions
  • About 2 minutes
  • Report by email

Bill C-26 (now Bill C-8) readiness assessment

Quick context

What's bringing you to Bill C-26 today?

What is Bill C-26?

Bill C-26 was Canada's federal cyber security bill. It died at prorogation in January 2025 and was reintroduced as Bill C-8, which received Royal Assent on 2026-06-15 (S.C. 2026, c. 9). It amends the Telecommunications Act and enacts the Critical Cyber Systems Protection Act for critical infrastructure.

Who does the CCSPA apply to?

The Critical Cyber Systems Protection Act applies to designated operators of critical cyber systems in six federally regulated sectors: telecommunications, interprovincial or international pipeline and power line systems, nuclear, federally regulated transportation, banking, and clearing and settlement. Government sets the operator classes by regulation and, as of 2026-08-27, has not: Schedule 2 is empty, so no organisation carries CCSPA duties yet. Vendors are reached through their customers' contracts.

What are the obligations under the CCSPA?

A designated operator must establish a documented cyber security program (within 90 days of designation), report incidents to the Communications Security Establishment within a window not to exceed 72 hours, manage supply-chain and third-party risk, comply with cyber security directives, and keep records. Penalties run high for non-compliance.

We do. This assessment scores where you stand against the framework, and stops there. The next step is the engagement behind that score: what we audit, what we build, and who runs it. Start there if you would rather have the gaps closed than catalogued.

Common questions

The Telecommunications Act amendments took effect on Royal Assent (2026-06-15). The CCSPA's substantive operator obligations phase in by Governor in Council order, and as of 2026-08-27 no order has been made and no date announced. Preparing now is reasonable, because the core program duties are already defined in the Act, so the work does not change when the order lands.

The Act binds designated operators, not their vendors, directly. But operators carry a legal duty to manage supply-chain and third-party risk. In practice that flows to suppliers through contract terms, security questionnaires, and audit rights. If you serve a designated operator, expect their obligations to land on you.

Designated operators must report a cyber security incident affecting a critical cyber system to the Communications Security Establishment within a window not to exceed 72 hours of discovery. Immediately after, the operator must also notify its sector regulator.

Once the Act is in force, the CCSPA carries administrative monetary penalties up to $500K per violation for an individual and up to $15M per violation for an organisation, and each day of non-compliance counts as a separate violation. The House cut the individual maximum from $1M to $500K before the bill passed, so older summaries still quoting $1M are out of date. Part 2 awaits an order in council, so nothing is payable yet. Regulatory offences can add fines and imprisonment, and directors or officers can be held personally liable.

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