On 1 June 2026, Manitoba granted Royal Assent to Bill 49 and Bill 51. Bill 49 amends The Business Practices Act to prohibit personalized algorithmic pricing for Manitoba consumers without their prior consent. Bill 51 enacts the Public Sector Artificial Intelligence and Cybersecurity Governance Act. Both statutes are now in force in Manitoba.
Bill 49 amends The Business Practices Act by defining personalized algorithmic pricing and prohibiting its use without consumer consent. The definition covers any price set, recommended, or varied for a specific consumer through an algorithm. The algorithm must draw on data including browsing history, spending patterns, device profiles, inferred willingness to pay, income level, credit history, location, or medical history. Using personalized algorithmic pricing without consent constitutes an unfair business practice, enforceable by the Consumer Protection Office. Bill 51 requires covered public sector entities to publish AI accountability and risk management plans, document AI systems in use, and refrain from uses prohibited by future regulation.
Retailers, insurers, financial institutions, and online platforms serving Manitoba consumers must audit their pricing algorithms against Bill 49's consent standard. Any algorithm that personalizes a price to an individual using the enumerated data categories requires an opt-in consent mechanism. For Bill 51, government agencies, regional health authorities, universities, school divisions, and municipalities must appoint accountability owners and document AI systems in use. They must also publish governance documentation before deploying AI in public services.
Bill 49's consent requirement applies to personalized pricing but not to general dynamic pricing, promotional pricing, or loyalty programme pricing that is not individualized to a specific consumer's profile. Bill 51's prohibited AI uses will be defined by future regulation; those regulations have not yet been published. Transition timelines for both Acts will be set by proclamation.
Licentium advises businesses and public sector bodies on Canadian AI and consumer protection regulation. Our work covers algorithmic pricing compliance audits, consent mechanism design, and AI governance programme development for public institutions; contact us to discuss your requirements. Work we undertake includes AI risk assessments, governance programme implementation, cross-provincial regulatory mapping, and data protection compliance.