Monthly Archives: August 2025

DIACC Submission to the Government of Canada’s Consultation on a Possible Canada‑EU Digital Trade Agreement

About DIACC

The Digital ID & Authentication Council of Canada is a public–private coalition working to advance a trusted Canadian digital economy through open, industry-driven frameworks for identity, authentication, and trust services. DIACC stewards the Pan‑Canadian Trust Framework™ (PCTF). This consensus-developed, living industry standards-based framework aligns with national priorities and global norms to support interoperability, privacy, and digital trade readiness across sectors and borders.

Addressing the Consultation Scope

The consultation invites input on digital trade topics such as:

Digital identities, trust services, and authentication
Electronic transactions and e‑signatures
Cross‑border data flows and localization requirements
Consumer protection, fraud prevention, and cybersecurity
Digital inclusion and participation of MSMEs
Artificial intelligence and emerging technologies
Standards, interoperability, and regulatory alignment

This submission addresses each of these priority areas with a clear emphasis on the role of the PCTF and industry‑led standards in advancing Canada’s trade, regulatory predictability, and inclusion objectives.

Executive Summary of Recommendations

Mutual Recognition of Industry Standardized Trust Frameworks
Support interoperability between the PCTF and the EU’s eIDAS 2.0 framework to facilitate secure digital trade in regulated sectors (e.g., housing, finance, energy), while maintaining Canada’s ability to define and govern its trust standards to reflect domestic policy and legal norms.
Mutual Recognition of Trust Frameworks
Support interoperability between the PCTF and the EU’s eIDAS 2.0 framework to facilitate secure digital trade in regulated sectors (e.g. housing, finance, energy).
Economic Growth in Key Sectors
Enable standards-based digital trust infrastructure to promote inclusion, reduce friction, accelerate and unlock innovation in e-commerce, housing finance, energy trading, public services, and cross-border logistics.
Recognition of Digital Sovereignty
Acknowledge that frameworks like the PCTF deliver practical, scalable solutions that complement formal national and international standards, strengthening the country’s digital sovereignty by ensuring homegrown, democratically governed solutions play a core role.
Secure and Privacy‑Respecting Cross‑Border Data Flows
Align privacy and cybersecurity standards to preserve both trust and efficiency, enabling secure cross-border data sharing.
Cybersecurity, Fraud Prevention & Consumer Protection
Leverage shared industry- and government-level practices, including fraud mitigation, identity-proofing, and privacy‑by‑design, to protect consumers in cross-border digital transactions.
Digital Inclusion and MSME Participation
Ensure the agreement empowers micro, small and medium enterprises, especially in rural, Indigenous and remote communities, to participate securely in digital trade.

Industry‑Led Standards in Canada’s Digital Trade Toolkit

Industry frameworks, such as the PCTF, serve as deployable tools within a broader toolkit that includes national and international standards. While ISO or eIDAS establish global principles, industry-led standards:

Translate principles into workable operational guardrails (e.g. technical protocols, risk models).
Accelerate adoption through flexible, market-driven updates.
Preserve national sovereignty by ensuring Canadian-made governance structures retain accountability and transparency.
Bridge jurisdictional or regulatory gaps.
And prepare the ground for future alignment or recognition.

In the Canada-EU context, the PCTF has the scale, backing, and governance necessary to serve as a core commercial interoperability engine alongside formal standards.

Alignment with Consultation Topics

Digital Identities, Trust Services & Electronic Transactions

Support mutual recognition of digital credentials and trust service providers under eIDAS 2.0 and PCTF.
Promote technology-neutral, cross-recognized approaches to e‑signatures and authentication.
Enable market actors to use Canadian or EU‑based trust providers under harmonized rules, fostering innovation and consumer confidence.

Cross‑Border Data Flows & Localization

Advocate for privacy-respecting data mobility in sectors like real estate, energy, finance, and logistics.
Oppose unnecessary data localization requirements that add cost without commensurate privacy or security gains.
Ensure that Canadian data flows operate in accordance with Canadian laws and values, even when exchanged across borders.
Encourage alignment of privacy and cybersecurity approaches that preserve trust and legal clarity.

Cybersecurity, Fraud Prevention & Consumer Protection

Recommend the adoption of shared fraud scoring, risk assessment, and identity verification frameworks.
Embed privacy‑by‑design principles into digital transactions and identity services.
Coordinate cross-jurisdictional responses to cyber incidents, identity theft and digital scams.Standards & Interoperability
Promote adoption of open international standards for identity, authentication, data portability, and interoperability.
Explicitly include industry‑driven frameworks, such as PCTF, as recognized tools for implementation.
Ensure Canada retains the ability to define, adapt, and govern its digital identity and trust frameworks independently, in alignment with national law, values, and economic strategy.
Leverage PCTF to reduce regulatory fragmentation and increase interoperability across sectors.

Digital Inclusion & MSME Access

Ensure MSMEs can access affordable, certified trust services for cross-border commerce.
Support inclusive access in underserved communities, including rural and Indigenous, via interoperable service models and affordable trust credentials.

Artificial Intelligence & Responsible Data Use

Align responsible AI principles for trust services and risk modelling, emphasizing transparency, fairness, and accountability.
Apply these principles to AI-enabled identity verification tools used in cross-border trade and digital wallets.

Sectoral Impact Examples

Sector	Benefit from Mutual Recognition of PCTF & eIDAS
Housing	Streamlined mortgage and property transactions; AML compliance with reduced friction
Energy & Resources	Certified credentials for emissions tracking, trade, and grid interoperability
Finance & Insurance	Reduced friction in cross-border lending, payments, and claims processing
Public Safety & Health	Trusted sharing of credentials for emergency response and cross-border healthcare

Conclusion

Canada has a unique opportunity, through this consultation, to shape a forward-looking Digital Trade Agreement with the EU, one that prioritizes trust, privacy, interoperability, digital sovereignty, and inclusion.

By integrating Canadian-governed, industry-led standard frameworks, such as the PCTF, into this toolkit alongside national and international norms, Canada can lead in building a scalable, resilient, and trusted digital trade architecture, without compromising its ability to govern its digital future.

DIACC welcomes further collaboration to refine the role of PCTF in Canada’s digital trade strategy and ensure that Canadian businesses, especially MSMEs, can participate confidently in secure, cross-border digital commerce.

Spotlight on Giesecke+Devrient (G+D)

1. What is the mission and vision of Giesecke+Devrient (G+D)?

We shape trust in a digital world.

We create innovative security solutions for the reliable protection of highly critical sectors. We engineer customized security technologies with passion and precision.

2. Why is trustworthy digital identity critical for existing and emerging markets?

Trustworthy digital identity is foundational to the secure functioning of both existing and emerging markets. As digital interactions become integral to daily life, ensuring the authenticity and security of these interactions is critical. Reliable digital identities enable secure access to services, protect against fraud, and foster user confidence. In emerging markets, they are instrumental in promoting financial inclusion and enabling access to essential services, thereby driving economic growth and social development.

3. How will digital identity transform the Canadian and global economy? How does your organization address challenges associated with this transformation?

Digital identity is poised to revolutionize the Canadian and global economy by streamlining access to services, enhancing security, and fostering innovation. It enables seamless interactions across sectors such as finance, healthcare, and government services, reducing friction and building trust in digital transactions.

Giesecke+Devrient (G+D) addresses the challenges of this transformation by offering secure, user-centric digital identity solutions. Our technologies ensure data privacy, comply with international standards, and are adaptable to various regulatory environments. By focusing on interoperability and scalability, we support the development of robust digital identity infrastructures that can evolve with the changing needs of societies and economies.

4. What role does Canada have to play as a leader in this space?

Canada is uniquely positioned to lead in digital identity and trust services due to its strong regulatory frameworks, commitment to privacy, and collaborative approach among public and private sectors. By investing in secure digital infrastructures and fostering innovation, Canada can be a leader in setting global standards for digital identity solutions that are inclusive, secure, and user-friendly. G+D supports these initiatives by providing technologies that align with Canada’s vision for a trustworthy digital ecosystem.

5. Why did your organization join the DIACC?

G+D joined the Digital ID & Authentication Council of Canada (DIACC) to collaborate with industry leaders in shaping the future of digital identity. We recognize the importance of a unified approach to developing secure, interoperable, and user-centric identity solutions. Through our membership, we aim to contribute our global expertise in security technologies to support DIACC’s mission of advancing digital identity innovation in Canada.

6. What else should we know about your organization?

Our organization, G+D, has a rich global history of being a pioneer in the industry, achieving numerous milestones that have set standards worldwide. In addition to our Canadian firsts, G+D has been a leader in innovation on a global scale, consistently demonstrating our commitment to advancing security technology and improving user convenience across various markets.

Globally, G+D was one of the first companies to introduce banknote processing equipment back in the early 20th century, revolutionizing how financial institutions handled currency. This innovation laid the groundwork for our later advancements in secure currency technologies. We were also pioneers in developing and implementing smart card technologies, which have become fundamental in today’s digital security applications, including telecommunications, banking, and government identity systems.

In the realm of telecommunications, G+D was instrumental in the development and widespread adoption of SIM cards, which transformed the mobile phone industry by enabling secure and personalized services. This innovation not only advanced mobile technology but also significantly enhanced security and functionality for mobile device users worldwide.
Moreover, G+D has been a leader in the development of secure identity solutions, providing governments and organizations with advanced technologies for passports, national IDs, and other secure documents. Our innovations in biometric and encryption technologies have helped shape global standards for identity verification and data protection.

Our commitment to sustainability is also evident on a global scale. We have been involved in developing eco-friendly technologies and materials for our products, significantly reducing the environmental impact of our manufacturing processes and end products.

By highlighting these global achievements alongside our Canadian firsts, it is clear that G+D’s legacy of innovation spans not only decades but also diverse industries and markets. Our forward-thinking approach and investments in new technologies continue to drive our mission of making people’s lives more secure and convenient, while also respecting our planet. As we move forward, G+D remains dedicated to being a leader in digital identity and authentication, setting new benchmarks for excellence and sustainability worldwide.

Spotlight on NOETRONIQ Strategic Initiatives

1. What is the mission and vision of NOETRONIQ Strategic Initiatives?

Mission:
To empower organizations with trusted, interoperable identity solutions by delivering expert architectural guidance rooted in privacy, security, and open standards.

Vision:
To shape a resilient digital future where individuals and institutions interact with confidence, enabled by transparent, decentralized identity ecosystems and intelligent trust frameworks.

2. Why is trustworthy digital identity critical for existing and emerging markets?

Digital trust and identity verification are foundational to securing interactions in today’s global digital economy. In both mature and emerging markets, they underpin everything from financial access to cross-border compliance and fraud prevention. But as the threat landscape evolves, driven by increasingly sophisticated actors and accelerated by AI, traditional security models are no longer sufficient. Verifiable identity becomes the anchor for ensuring accountability, protecting privacy, and enabling secure, scalable systems. In a world of rapid digital and AI-driven transformation, strong identity infrastructure is not just about access; it’s about resilience, governance, and trust at every layer of interaction.

3. How will digital identity transform the Canadian and global economy? How does your organization address challenges associated with this transformation?

Digital trust and identity verification will redefine how value, services, and decisions flow across both the Canadian and global economies. As digital interactions become more decentralized, cross-border, and mediated by AI, trusted identity is the linchpin for enabling secure access, protecting user autonomy, and ensuring compliance at scale. In Canada, this transformation supports economic inclusion, public service modernization, and global interoperability through frameworks like the PCTF. Globally, it empowers new markets, mitigates fraud, and creates the foundation for verifiable, privacy-respecting ecosystems.

NOETRONIQ Strategic Initiatives addresses these challenges by offering expert architectural guidance to help organizations align with evolving standards, integrate verifiable credentials, and future-proof their identity infrastructure. Our focus is on building resilient, interoperable systems that embed trust by design. Bridging policy, technology, and security in a rapidly shifting digital and AI-enhanced landscape.

4. What role does Canada have to play as a leader in this space?

Canada is well-positioned to lead in digital trust and identity verification by advancing inclusive, privacy-respecting, and interoperable frameworks. With the Pan-Canadian Trust Framework and a strong tradition of public-private collaboration, Canada offers a model for securing digital ecosystems that scale across borders. As global trade and digital services expand, Canada’s leadership in trustworthy identity infrastructure strengthens its role as a reliable partner in international commerce. By prioritizing security, accountability, and user control, Canada can shape the standards and governance models that underpin a resilient, globally connected digital economy.rust services, across many industries, including Auto Finance.

5. Why did your organization join the DIACC?

NOETRONIQ Strategic Initiatives joined the DIACC to contribute to and align with the collaborative development of Canada’s digital identity and trust ecosystem. As a firm specializing in identity architecture, verifiable credentials, and privacy-first design, we see DIACC as a critical forum for shaping interoperable, standards-based solutions that serve both national interests and global alignment. Participation in DIACC enables us to engage with leading experts, support the evolution of the Pan-Canadian Trust Framework, and ensure our clients’ solutions are future-proof and policy-aware. We believe that trusted identity is foundational to a resilient digital economy—and that collaboration is key to getting it right.

6. What else should we know about your organization?

NOETRONIQ Strategic Initiatives brings deep expertise in digital identity architecture, cybersecurity, and verifiable credentials, with a focus on building systems that are both technically robust and aligned with emerging governance models. We operate with the precision and foresight of a strategic partner, helping clients navigate complexity at the intersection of policy, privacy, and technology. We’re especially attuned to the shifting landscape brought on by AI, decentralized infrastructure, and evolving trust frameworks. Our mission is to help shape a digital future where identity is secure, user-controlled, and interoperable by design.

The Digital ID and Authentication Council of Canada (DIACC) Written Submission for the Fall 2025 Pre-Budget Consultations

Submitted by: Joni Brennan, President

List of recommendations:

Recommendation 1: That the government fund and deploy an interoperable, reusable digital credentials login solution for federal services modeled after widely-used single sign-on tools in the private sector.
Recommendation 2: That the government invest in Canadian-based trust infrastructure, including domestic cloud and data centres, to support AI-readiness, digital sovereignty, and economic resilience.
Recommendation 3: That the government advance interoperability to unleash digital trade and labour mobility.

Introduction

Thank you for the opportunity to provide input in advance of Budget 2025. In a time of economic, technological, and geopolitical uncertainty, Canada must act with urgency to reinforce the foundation of a strong, secure, and competitive digital economy: trust.

Whether enabling interprovincial labour mobility, reducing fraud in real estate and finance, or ensuring AI tools are used responsibly, verifiable trust infrastructure is central to our countryʼs economic stability and resilience. Trust is not just a principle, it is the experience citizens have when interacting with government services that are as seamless, secure, and intuitive as private-sector platforms. Without secure and scalable identity verification, Canadian businesses face rising fraud costs, compliance burdens, and lost consumer confidence. Citizens and professionals are delayed in accessing critical services or moving where they are needed most. And governments are challenged to keep pace with accelerating threats in an AI-driven world.

Now is the time to deliver trust through experience by investing in practical tools and Canadian infrastructure that protect citizens, unlock innovation, and future-proof our economy.

About DIACC

The Digital Identification and Authentication Council of Canada (DIACC) is a non-profit public–private coalition created following the federal Task Force for the Payments System Review. DIACCʼs mission is to accelerate digital trust adoption by enabling privacy-respecting, secure, and interoperable identity systems.

DIACC is the steward of the Pan-Canadian Trust Framework (PCTF) — an industry-developed, standards-based, technology-neutral framework designed to enable scalable, certifiable digital trust infrastructure that meets the needs of governments, businesses, and individuals.

The PCTF has been developed in collaboration with experts from federal, provincial, and territorial governments as well as industry and civil society. It supports verifiable credentials, authentication services, fraud prevention, and information integrity across the Canadian digital economy.

Canadaʼs Urgent Trust Deficit

Canada faces a growing trust deficit that threatens economic growth, competitiveness, and national resilience. Three converging challenges demand action:

AI-accelerated misinformation and identity theft – Generative AI tools are enabling the rapid creation and dissemination of fake identities, fraudulent documentation, and disinformation. Without robust authentication systems and verifiable credentials, the authenticity of people, data, and services becomes harder to determine—eroding consumer confidence and legal certainty.
Rising fraud and its impact on the economy – Many of Canadaʼs key sectors are increasingly subject to fraud. The real estate sector, for example, is increasingly experiencing impersonation and illicit financial flows, especially in transactions involving unrepresented parties. Mortgage fraud, title theft, and manipulated documentation are rising, yet identity verification practices remain outdated and fragmented.
Barriers to labour mobility and seamless trade – Many professionals face long delays and duplicative processes when seeking to work across provinces or internationally. Businesses struggle to comply with evolving regulatory requirements and to compete globally without recognized, verifiable credentials.

Recommendations

DIACC offers three core recommendations to address these threats and seize the opportunity to lead globally in trusted digital innovation.

Recommendation 1: That the government fund and deploy an interoperable, reusable digital credentials login solution for federal services modeled after widely-used single sign-on tools in the private sector.

The Government of Canada should develop and implement a digital credentials login solution that enables citizens to access federal services with one secure, consistent experience — similar to how they use Google or Apple sign-in options across the internet. For example, with a trusted credential, Canadians could log into a real estate registry, file taxes, or access health records using one verified identity, reducing friction and fraud risk while improving convenience and access.

These credentials should be certified against open standards such as the PCTF, enabling individuals to verify their identity once and reuse it securely across services. The government is also encouraged to take a longer-term view by building compatibility across federal, provincial, and municipal digital credentials systems.

Recommendation 2: That the government invest in Canadian-based trust infrastructure, including domestic cloud and data centres, to support AI-readiness, digital sovereignty, and economic resilience.

Verification and authentication tools are essential infrastructure in an AI-driven economy. As AI-generated content, synthetic identities, and manipulated documents become increasingly sophisticated, the ability to verify the provenance and traceability of information and data becomes even more vital.

DIACC recommends that the government:

Recognize authentication and verification tools as critical components of Canadaʼs AI strategy and cybersecurity agenda.
Fund the adoption and certification of privacy-respecting, standards-based solutions, such as the PCTF.
Prioritize collaborative development of tools that verify identity, documentation, and information authenticity while preserving user privacy.
Ensure data residency through investment in Canadian-based private cloud and hardware services.

A proactive, standards-aligned approach will support:

Responsible AI deployment across sectors.
Secure digital service delivery.
Reduced liability for businesses and professionals relying on verified information.
Greater resilience against misinformation and fraud in elections, commerce, and public discourse.

Recommendation 3: That the government advance interoperability to unleash digital trade and labour mobility.

Interoperability is key to reducing friction, unlocking economic opportunity, and ensuring Canada remains globally competitive. DIACC recommends that the government:

Support cross-government and cross-border interoperability by recognizing frameworks such as the PCTF in legislation, procurement, and policy.
Advance mutual recognition of trust frameworks with international partners (e.g., between PCTF and the EUʼs eIDAS 2.0 framework).
Enable the use of verified credentials for regulatory compliance, licensure, and interprovincial labour mobility.
Accelerate digital transformation across public services using certifiable trust services.

This approach will help:

Enable professionals and skilled workers to move between provinces without redoing verification processes.
Simplify cross-border regulatory compliance for Canadian exporters and importers.
Allow micro, small and medium enterprises — including in rural, Indigenous and remote communities — to offer services and products across Canada and beyond without prohibitive onboarding costs.
Ensure that public sector modernization efforts are secure, accessible, and efficient.

The Road Ahead

Canada is at a turning point. The foundation of trust that underpins our digital and economic systems is under strain, but the tools and standards to reinforce it already exist. Frameworks like the PCTF offer governments and businesses practical, scalable solutions that:

Meet privacy, security, and accessibility requirements.
Support inclusive digital access for underserved communities.
Complement formal standards and enable rapid deployment.
Preserve Canadaʼs digital sovereignty. Budget 2025 offers a strategic moment to invest in these tools, not just as a technical fix but as a long-term economic, national security, and democratic priority.

Conclusion

Trust is Canadaʼs most valuable economic asset in the digital age. Whether enabling a small business to sell across borders, a citizen to access services securely, or a hospital to verify a clinicianʼs credentials during a crisis, trust infrastructure is the connective tissue of our digital society. DIACC welcomes further collaboration with federal partners to ensure Canadians can interact, transact, and innovate with confidence in a digital-first world. Thank you once again for the opportunity to provide our input in advance of Budget 2025 and as we collectively move forward on the path to a digitally and economically prosperous Canada.