A few weeks ago, I wrote about “The CRTC’s regulatory twilight zone”, where Canada’s communications regulator appears to be disconnecting expectations from reality. That post talked about the Commission’s requirement for ISPs to publish plan information in a standardized database format, as set out in its recent Telecom Regulatory Policy CRTC 2026-238: Making it easier for consumers to shop for Internet services.

Apparently, the CRTC was unaware that AI capabilities already embedded in web browsers can compare prices today, with a query such as “which mobile carrier has the best offer for US roaming and 100GB of data and free nationwide Canada calling and texts?” No standardized database format required. No regulatory mandate needed.

Indeed, a few weeks ago, the UK regulator (Ofcom) released an update on its research, “Exploring what impact the adoption of AI could have on the experience of telecoms customers”. A note by Dean Bubley (Disruptive Analysis) observed that the report was released in the same week that Meta’s new Muse AI agents started helping people manage or renegotiate their subscriptions in the US.

Let’s look at another issue that is bound to arise: commitments to a typical internet speed. My September post referred readers to Ted Woodhead’s concerns about how the Commission defines “typical” when the service providers commit to delivering internet service. “The typical download and upload speeds are the speeds customers should expect to receive at all times which ISPs have committed to delivering during pre-sale.”

The speeds customers should expect to receive at all times. That is a pretty strong requirement, and may set an unachievable expectation in the minds of many consumers.

Unachievable, not because the service providers aren’t delivering what they promise. Unachievable because consumers may not be able to accurately measure the service quality being delivered.

There are many forms of interference that result in disconnecting expectations from reality. Roger Entner of Recon Analytics recently talked about problems introduced inside the customer’s household: a “label tax – the difference between what you buy and what you get”; and, a “Wifi tax – a mismatch between your router and your laptop”. Writing on X, he summarizes some of them as “Buy 5 Gbps fiber, but your motherboard tops out at 1 Gbps. Then Wi-Fi can take another ~90%, so a gig plan turns into 100 Mbps on the laptop. Who owns that experience, the ISP or the device ecosystem?”

When the subscriber runs Speedtest on their computer, how will they account for the other devices sharing their home network? Or devices that are injecting interference into their home network?

“Who owns that experience, the ISP or the device ecosystem?”

How many complaints to CCTS will be generated by this expectational mismatch? How will CCTS handle such complaints?

As I noted in my newsletter at the end of September, I am concerned that Canadian telecom policy is following a regressive, reactive path, adding regulations despite the presence of intense facilities-based competition. I recognize that the CRTC had to respond to the legislative changes to the Telecom Act enacted by Parliament in 2024. However, the Commission had flexibility under those provisions to be far less prescriptive in its decision, anticipating and even encouraging investment in more advanced AI capabilities by consumers and service providers alike.

Another missed opportunity.

In June, the CRTC launched a proceeding with the stated intent of making consumer protections for communications services more clear and more consistent by combining the four separate codes (home phone, wireless, internet, and TV) into a single unified Code (the Consumer Protection Code), while reducing administrative burden.

A number of the initial submissions express concerns that simply combining four Codes into a single document does not make the regulatory framework simpler or contribute to reducing administrative burden. The Commission’s Working Document – a proposed unified Code – runs 33 pages.

The Canadian Telecommunications Association (CTA) cautions that the Working Document isn’t clearer or simpler. “Those objectives require the Commission to assess whether existing requirements remain necessary, proportionate and appropriate considering current market conditions, and whether they can be simplified, modernized or eliminated.”

Among the 24 questions posed to intervenors, only one (Q.12) asks “Are any other updates to the rules for early cancellation fees for wireless services needed to account for other evolving industry trends?”

Shouldn’t that be asked of every clause in the document? Shouldn’t the CRTC be looking for ways to update all of its rules?

CTA wrote:

The Commission should use this proceeding as an opportunity to modernize and rationalize, rather than simply amalgamate, the existing consumer protection framework. Consistency should be pursued where there is a sound policy basis for treating services alike, but differences should be retained where the nature of the service, the consumer issue being addressed or the costs of compliance justify different treatment. Similarly, where market and technological developments have overtaken the circumstances that originally justified a requirement, harmonization should provide an opportunity to simplify or remove that requirement rather than extend it to additional services.

Along those lines, TELUS says that choice and competition in the TV market “have rendered prescriptive protections unnecessary and largely irrelevant to consumers.” TELUS says there is no need for the new unified Code to include TV.

Similarly, certain prescriptive elements of some of the individual codes have not kept up with changes in the marketplace.

In its Working Document, the CRTC proposed to extend a $50 cap on data overage charges (that currently applies to wireless services) to Internet services. In a world of unlimited residential high-speed internet, is that really necessary?

The lowest priced iPhone in 2025 retailed for C$999 as contrasted with the highest price for an iPhone in 2015, C$769. An iPhone 18 Pro Max with 2TB of storage is currently listed at C$3,699. Amortizing such a device over two years at 0% financing costs more than $150 per month. Can’t we treat consumers like adults and let them have the option of spreading increased device costs over a longer period of time than the maximum 24 months set out by the CRTC more than 13 years ago?

In the interest of administrative simplicity, a number of submissions called for the CRTC to clearly assert federal jurisdiction over consumer protections for communications services. Otherwise, service providers will be left having to navigate the Commission’s unified Code, as well as 13 provincial and territorial regimes setting out inconsistent regulations.

I frequently write about regulatory stability and Calvinball. Last week, I wrote that government operates under different pressures than business. I’m not sure that the regulator appreciates the impact of some of its decisions on service providers operating businesses at scales of more than 10 million consumers.

There is a cumulative impact of decisions on the stability of business operations. With hundreds of retail outlets, thousands of customer service representatives, even small changes to retail consumer regulations can lead to changes in business processes, information systems, point of sale terminals, and training for customer service representatives and third party agents.

As the Commission continues down this path, we should ask, “for whom are we reducing administrative burden?”

According to the CRTC’s “Coming Attractions” page, there is a plan to issue a Telecom Notice of Consultation this week, with a “Call for comments – Reducing red tape – Review of telecommunications reporting requirements”. [Updated October 6, 2026 1:15pm with link to Notice of Consultation] The Commission might want to consider whether this should be a continuous process, inherent in every proceeding.

What is the cost of implementing administrative simplicity? Will these changes deliver value for consumers, service providers, both, or none of the above?

I’ve often talked about the glacial pace of regulation on the Telecom side of the CRTC. It turns out the Broadcasting side is faring no better.

For more than a year, Canada’s broadcasting and telecom sectors have been told that the CRTC is “building a house.” In May, CRTC Chair Vicky Eatrides described the Commission’s agenda as a careful construction project: laying foundations, erecting framing, ensuring the structure will last. Vice chair Adam Scott had used the same metaphor in his remarks to the Scotiabank TMT Conference, emphasizing patience, sequencing, and the importance of getting the architecture right.

But metaphors only work when they illuminate reality. Increasingly, this one obscures it. While the CRTC continues to talk about building a house, the industries it oversees are watching the neighbourhood burn.

The frustration has been documented (repeatedly) by the people who appeared before the Commission, expressing both urgency and optimism.

In early January of 2025, the CRTC launched a proceeding, The Path Forward – Working towards a sustainable Canadian broadcasting system. The oral hearing took place in June 2025; the paper filings were completed a year ago.

In a widely shared LinkedIn post, Steve Jones of Stingray Radio recounts appearing at the hearing “to plead for the modernization of content regulations at Canadian radio.” His summary is blunt: “One year later. Absolutely nothing has happened.” No modernization of CanCon definitions. No movement on ownership caps. No recalibration of exposure requirements. Not even minor progress. Eight more stations have gone dark in the meantime.

Rod Schween of Pattison Media echoes the same experience in a separate LinkedIn post. He says he arrived at the hearing with “cautious optimism,” believing the Commission understood the severity of the pressures facing broadcasters. Six months later, he heard the Chair’s house‑building metaphor. He says he is still standing outside the construction site asking the same question: “How long does it take to build a house?”

These are voices representing hundreds of stations, thousands of employees, and communities across the country relying on local media for emergency information, civic coverage, and cultural expression.

The CRTC’s glacial pace is actively harmful.

Steve Jones illustrated the contrast between technological change and regulatory inertia. He observed that in the year since the proceeding closed:

• Smartphones learned to communicate directly with satellites.
• AI learned to create and buy advertising campaigns.
• Car dashboards became global multimedia platforms.

Meanwhile, “Canada’s radio content and ownership rules didn’t move a millimetre.” Stations are still regulated by the number of AM and FM transmitters they own, as though those transmitters compete only with each other and not with a global ecosystem of unregulated digital platforms.

Technology is advancing in months, while the pace of CRTC regulation is measured in years. This mismatch is a structural failure, no different from the failed regulatory hypothesis I described in May, highlighting the investment consequences of regulatory uncertainty. Capital does not wait for proceedings. It does not pause for consultations, reconsiderations, or multi‑year sequencing exercises. It flows to jurisdictions where the rules are clear, predictable, and aligned with market realities.

Canada’s broadcasting and telecom sectors need a regulator that understands that the cost of delay is not theoretical. Regulatory uncertainty and delay can be measured in shuttered stations, reduced newsrooms, deferred and reduced investment, and diminished Canadian ownership.

A commenter on the Jones post said the CRTC “eliminated license renewals to free up staff to focus on more impactful policy changes. So annnnnny year now.” The joke lands because the underlying truth is clear: the Commission’s internal processes are not producing timely outcomes.

The CRTC speeches describe a careful, methodical construction project. But a house that takes too long to build is of no use if the intended occupants don’t survive long enough to move in.

Steve Jones says, “It is as if the house is on fire, and we’ve called 9‑1‑1… and been put on hold. For a year.”

Rod Schween is equally pointed: broadcasters are standing outside in the cold, waiting for the keys to a house that should have been finished long ago.

While the CRTC talks about framing and foundations, the broadcasting industry is talking about survival. These two conversations simply aren’t aligned.

Unfortunately, government operates under different pressures than business. Government studies, consults, reports, and eventually acts. But, eventually just isn’t good enough in today’s business environment. The business world can’t wait for Canada’s regulator to finish getting its house in order.

The fires are spreading while the Commission is still fiddling with blueprints.

I sonetimes think the CRTC’s regulatory twilight zone is situated in a place beyond that which is known to mere mortals. If you want to cross over into that disconnected world, join me as we examine the CRTC’s latest consumer broadband directive, Telecom Regulatory Policy CRTC 2026-238, issued just under 2 weeks ago (September 10). “You are about to enter another dimension, a dimension not only of sight and sound but of mind. A journey into a wondrous land of imagination.”

As my friend and colleague Ted Woodhead pointed out in his recent blog post, this policy decision raises several confusing issues for consumers and ISPs alike. Ted took aim at the Commission’s redefinition of “typical” internet speeds. While the CRTC originally flirted with defining “typical” as a speed delivered 95% of the time, they ultimately threw logic out the window and decided “typical” means a speed ISPs must deliver at all times.

As Ted noted, transforming a “typical” expectation into an absolute, 100% guarantee defies basic network physics.

But, as baffling as the “typical speed” semantic gymnastics are, that might not be the strangest part of the decision. For that, we’ll take a journey into that “wondrous land of imagination.” I refer to the new mandate requiring ISPs to publish all retail plan data on their websites in highly structured, machine-readable CSV spreadsheets. You’ve just crossed over into the Twilight Zone.

The Commission decided that a more “dynamic marketplace” would emerge, if only ISPs were to publish all their Internet plan data in a machine-readable format. That way third-party developers could build automated comparison-shopping engines using the ISP provided data. While the CRTC did not explain why ISPs should help third parties make money off ISP labour, it did determine that the data must be provided in a standardized database format. And in doing so, the CRTC looked south for inspiration, explicitly pointing to the FCC’s technical guidelines for broadband machine-readable files as its blueprint.

There is just one glaring problem: The FCC already killed those exact rules.

A month earlier (August 13), the FCC took a hard look at its own broadband label experiment and realized that backend spreadsheet files were a costly compliance headache that nobody was using:

We also conclude that the substantial compliance burdens imposed by this requirement are not justified by the minimal, if any, likely benefits for consumers. The current record offers a fuller description of the relevant compliance burdens than was available to the Commission in 2022. We also find insufficient evidence that the requirement is needed to facilitate transparency and consumer decision-making, as some commenters argue. …And there is no record evidence that any third parties have used machine-readable label content to develop pro-consumer tools.

Real-world consumers don’t shop via raw CSV data, and the expected wave of tech developers building comparison apps never materialized. So, the FCC sensibly chopped the requirement to reduce regulatory burden and costs.

Yet, the CRTC eagerly copy and pasted the homework of a neighbor who had already thrown it in the trash.

Adding another layer of unnecessary administrative nonsense, the CRTC acknowledged that US and Canadian plan metrics don’t align, so while the format for the data requirement that the FCC just eliminated will serve as a starting point, the Commission punted the final file layout to the CRTC Interconnection Steering Committee (CISC), giving them until September 2027 to “Canadianize” the already dead American technical specification. That’s right – a year from now.

By the time Canadian carriers spend millions configuring their databases to output these complex backend files, the rules will be built on the skeleton of an obsolete framework that the US abandoned for being useless. You have entered another dimension.

It is a classic case of regulatory FOMO (Fear Of Missing Out) — except Canada is missing out on the actual lessons learned, preferring instead to import the administrative burdens our neighbors were smart enough to get rid of.

Investors from around the world recently met in Canada and implored Canadian governments and regulators to make Canada an easier place to invest. I have written before about those calling for “Ottawa to remove the obstacles that currently deter companies from investing in this country.”

The CRTC continues to do the opposite, adding regulations that do little to help consumers and only increase the cost of doing business.

Is there a role for the CRTC in regulating AI wholesale?

Every few years, Canadian telecom finds a new frontier onto which old regulatory debates are projected. A recent Cartt.ca op‑ed arguing that carriers must “answer the AI wholesale question” is the latest example. It’s thoughtful on commercial dynamics, but it misfires on the role of the CRTC. AI infrastructure is not telecom infrastructure, and trying to drag it into the regulatory orbit of wholesale fibre or aggregated access misunderstands both the law and the economics.

The op‑ed’s premise is that Bell and Telus are building large AI compute clusters—true—and that smaller firms may want resale access—also true. But the leap comes when it implies that the CRTC should eventually adjudicate questions about GPU allocation, bundling, or resale eligibility. That is where the argument breaks down.

AI compute is not a telecommunications service under the Telecommunications Act. It is not carriage, transmission, or routing of information. It is a cloud‑adjacent, data‑centre‑based computing service. The fact that Bell and TELUS happen to own networks does not magically convert their AI businesses into regulated telecom offerings. If Rogers builds a movie studio, the CRTC does not regulate wholesale access to the cameras. If TELUS builds a health‑tech platform, the CRTC does not regulate wholesale access to the diagnostic algorithms. Vertical adjacency is not jurisdiction.

The op‑ed also treats AI compute as if it were analogous to wholesale broadband. It isn’t. Wholesale telecom regulation exists because networks exhibited certain characteristics associated with duplicating last‑mile access. GPU clusters do not. AI data centres are capital‑intensive, but they are not monopoly bottlenecks. CoreWeave, Hut 8, AWS, Google, and a dozen Canadian data‑centre operators are all building capacity. The market is competitive, global, and expanding. The CRTC intervenes when competition cannot emerge; AI compute is the opposite case.

Even the bundling concern is misplaced. The op‑ed warns that carriers might combine network services with compute in ways that raise competitive questions. But bundling only becomes a regulatory issue when the underlying telecom component is itself subject to tariff or mandated wholesale access. If Bell sells fibre plus GPUs, the fibre portion remains regulated exactly as it is today; the compute portion remains a commercial cloud service. The CRTC does not — and should not — set rules for how private companies package unregulated products.

The op‑ed’s commercial questions are legitimate: Will there be resale? What are the minimum commitments? How will allocation work during peak demand? But these are questions for the marketplace to answer, not the regulator. The CRTC’s involvement would not create clarity; it would create uncertainty, slow investment, and entangle an emerging sector in legacy frameworks.

Canada needs more investment in AI infrastructure, more competition, and more innovation. The fastest way to get there is to let the market work — not to conscript the CRTC into regulating something that is not, by any stretch, a telecom service.