Manitoba introduces algorithmic pricing and public sector AI regulation

On June 1, 2026, two Manitoba bills governing artificial intelligence received Royal Assent. Bills 49 and 51 introduce consumer protection-focused legislation for private sector entities using algorithmic pricing and regulate the development and use of AI by public sector entities.

What you need to know

• Manitoba has prohibited the use of personalized algorithmic pricing for Manitoba consumers without their consent under the province’s Business Practices Act.
• Public sector entities may soon be subject to regulations on artificial intelligence systems and cybersecurity standards.

Public and private sector AI regulation in Manitoba

Bill 49 (the Amendment) amends the existing Business Practices Act, which is consumer-protection focused legislation designed to protect consumers from “unfair business practices”, including practices that may reasonably deceive or mislead consumers, or that may make false claims or representations. The Amendment deems the use of personalized algorithmic pricing without consumer consent to be an unfair business practice. “Personalized algorithmic pricing” is described as the use of algorithms, data analytics, machine learning, or artificial intelligence to target pricing to each individual consumer based on data collected, analyzed, or processed about that consumer without consent. Businesses found to be engaging in unfair business practices under the Business Practices Act may be subject to fines of up to $1,000,000 for repeat corporate offenders, investigation and prosecution by the Consumer Protection Office, and/or civil liability pursuant to the Business Practices Act’s civil right of action. Directors and officers can be held personally liable for authorizing unfair business practices.

Bill 51 enacts the Public Sector Artificial Intelligence and Cybersecurity Governance Act (the Act), which regulates the development and use of artificial intelligence systems by public sector entities (including governments and government agencies, health authorities, universities, school divisions, and municipalities). Similar to Ontario’s Enhancing Digital Security and Trust Act, the Act primarily paves the way for forthcoming regulations that will specify the public sector entities subject to the Act and the content of certain obligations. Entities subject to the Act will be required to be transparent about their use of such systems, develop applicable artificial intelligence accountability and risk management frameworks, and refrain from using artificial intelligence systems for purposes prohibited by regulation. The Act also empowers the legislature to enact cybersecurity requirements and technical standards for AI systems.

These new developments, paired with Manitoba’s 2024 enactment of The Intimate Image Protection Amendment Act (Distribution of Fake Intimate Images) that regulates the distribution of fake intimate images created using technology, illustrate Manitoba’s efforts to actively shape the influence of AI within the province.

Implications for businesses

Businesses engaging in algorithmic pricing for Manitoba consumers should carefully consider their operations to determine whether they fall within the scope of the prohibited practice, and consider modifications or enhancements, such as obtaining consent, to limit their risk.

Public sector entities in Manitoba should keep an eye out for regulations governing artificial intelligence and cybersecurity. Entities will be provided with an opportunity for public consultation on forthcoming regulations. Businesses that serve public sector entities ultimately governed by the Act can expect increased expectations and contractual requirements as they seek to meet their new obligations.