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.
