On 1 June 2026, Bill 51, The Public Sector Artificial Intelligence and Cybersecurity Governance Act, received Royal Assent in Manitoba and was registered as S.M. 2026, c. 43. The Act is enacted but not yet operational in substance. Most obligations it places on public sector entities will not apply until the Lieutenant Governor in Council makes regulations specifying which entities are subject to the Act and what each must do. Manitoba is the first Canadian province to enact dedicated AI governance legislation for its public sector.
The Act empowers the Lieutenant Governor in Council to make regulations on the following matters: disclosure of AI system use to persons affected by those systems; development of AI accountability and risk management plans; reporting of cybersecurity incidents; technical standards for AI system use and cybersecurity; and restriction or prohibition of AI systems for specified purposes. Section 2 binds the provincial government to comply with future regulations. Section 3 authorises extending obligations to prescribed public sector bodies by regulation. This enabling structure mirrors Ontario's Enhancing Digital Security and Trust Act, which similarly delegated substantive content to subordinate legislation.
Provincial government departments, regional health authorities, universities, school divisions, and municipalities in Manitoba fall within the Act's anticipated scope, subject to definition by regulation. Vendors deploying AI systems on behalf of Manitoba public sector bodies should monitor regulatory development, since procurement instruments may extend the Act's obligations to private parties. AI developers supplying software to Manitoba public institutions are advised to document system capabilities and risk characteristics in preparation for anticipated transparency and accountability requirements.
No substantive compliance obligations are in force. Draft regulations have not been published as of this post. Interested parties may engage the Manitoba government through regulatory consultation processes once draft regulations are released. The timetable for regulations has not been announced. Ontario's equivalent legislation saw approximately 18 to 24 months between Royal Assent and the first regulations, though Manitoba has not indicated it will follow the same timeline.
Licentium advises on AI governance and public sector compliance across Canadian and multi-jurisdictional settings. We assist clients in responding to regulatory consultations and in designing accountability structures in advance of legislative implementation. Work we undertake includes AI risk management plan design, public sector AI governance strategy, regulatory consultation drafting, and privacy and procurement advisory for AI deployments.