Appearance before the Standing Committee on Industry, Science and Technology (INDU) by the Minister of Innovation, Science and Industry - July 25, 2022

July 25, 2022

Canada’s Telecommunications network resiliency

Key Messages:

  • Telecommunications are vitally important for Canadians in their daily life.
  • Canadians were rightly frustrated with the unacceptable situation we saw with the Rogers outage.
  • That’s why Minister Champagne brought together the CEOs from Rogers and the other major telecommunications companies to discuss how important it is to improve reliability of the networks across Canada.
  • Canadians deserve more from the telecom sector and the Government of Canada will ensure it meets the high standard Canadians expect, including improving competition, innovation and affordability.

Supplementary Messages:

  • The CRTC will also examine this outage. Furthermore, the Minister directed the companies to reach agreements within 60 days on emergency roaming, mutual assistance, and improving public awareness around telecommunications emergencies.
  • Canada has been able to mitigate risks in the telecommunications system through public-private collaboration of the Canadian Security Telecommunications Advisory Committee (CSTAC).
  • CSTAC supports two key Government of Canada initiatives – the National Strategy for Critical Infrastructure and Canada’s Cyber Security Strategy. It allows private and public sectors to exchange information and to collaborate strategically on current and evolving issues that may affect the telecommunications infrastructure, including cyber security threats.
  • The resiliency of the telecommunications networks is the responsibility of telecommunications service providers. These companies have emergency plans and procedures, and work to ensure the quickest recovery possible to their infrastructure. This includes substantial investments in system resiliency since failure can have a substantial impact on their business and Canadians.

Background:

Early morning of July 8, 2022, Rogers experienced a widespread network outage across the country that lasted for more than 15 hours.

Millions of Rogers customers using their wireless and wireline services were impacted. In addition, public facing services such as 911 access by Rogers customers, debit transactions through Interac, government services provided by Service Canada, and city level services were also impacted.

As of July 9, 2022, wireless and wireline services have been restored for most customers and the rest restored shortly thereafter.

Emergency management – ISED roles and responsibilities

Key Messages:

  • The safety and security of Canadians is the Government of Canada’s top priority.
  • During emergencies where telecommunications infrastructure is affected, Innovation, Science and Economic Development Canada (ISED) supports telecommunications companies. It also coordinates with federal partners to support the rapid restoration and continuity of telecommunications networks.
  • The government is continually preparing plans and practicing measures to address all hazards.

Supplementary Messages:

  • ISED is the lead federal department on response to telecommunication emergencies. In those instances, it works closely with Public Safety Canada’s Government Operations Centre.
  • During emergencies, and upon requests from telecommunications companies, ISED provides assistance and works with other federal departments as required to support the restoration of telecommunication services.
  • Telecommunications companies have emergency plans and procedures and work to ensure the quickest recovery possible to their infrastructure during events. During the July 8 outage, Rogers did not request federal assistance from ISED.
  • Through working groups co-chaired by ISED and industry, service providers also engage directly with each other to render mutual assistance. ISED was made aware that Bell and TELUS did provide assistance to Rogers during the outage.
  • The individual companies involved would be best positioned to expand on the specifics of the assistance they delivered.
  • ISED does not own physical telecommunications networks and therefore, cannot carry out the physical repair of a telecommunications network.

Background:

ISED’s role

The Emergency Telecommunications Directorate within ISED is the federal lead for telecommunications in crisis situations. It takes an all-hazards approach to emergency management and works closely with federal and provincial emergency management organizations and the telecommunications industry across Canada.

The Canadian Telecom Resilience Working Group (CTRWG), comprised of telecom companies and ISED, collaborates on the development and implementation of plans and measures to prepare for, respond to and recover from incidents or events impacting the Canadian critical telecommunications infrastructure.

During an emergency response, ISED manages the information flow to and from telecommunications stakeholders and other government departments, particularly Public Safety Canada. ISED may become more deeply involved if a situation deteriorates. This could include fulfilling requests for assistance from the telecom community, such as for additional radio frequencies and for the acquisition and movement of goods or people (including cross-border).

ISED does not own physical telecommunications networks and therefore, cannot carry out the physical repair of a telecommunications network.

During the Rogers outage that occurred July 8:

  • ISED raised awareness of the outage to CTRWG members after learning of the outage.
  • A CTRWG member requested the CTRWG playbook be activated, and a teleconference held. Rogers attended that teleconference and provided an update on the situation as they understood it at the time.
  • CTRWG members offered assistance and engaged directly with Rogers for that purpose.
  • Bell and TELUS, who are members of the CTRWG, indicated that mutual aid was provided to Rogers.
  • In parallel ISED activated its Emergency Telecommunications Team and provided situational updates to federal partners.
  • No requests for federal assistance were received from Rogers.

Public safety broadband network

Key Messages:

  • The health and safety of Canadians is a top priority for the Government of Canada.
  • Emergency management and critical infrastructure are shared responsibilities across governments, industry, and individuals.
  • The government is committed to working with partners on the development of a secure Public Safety Broadband Network that can be used by emergency responders to communicate with each other in emergency situations, planned events, and day-to-day operations.
  • Moving forward with this network will be complex and will require all levels of government to support its development.

Supplementary Messages:

  • On March 17, 2022, federal, provincial, and territorial Ministers responsible for emergency management announced the release of the report entitled, A Public Safety Broadband Network for Canada: A Canadian Approach to Implementation of the Next Generation of Public Safety Communications.
  • The report, developed by the Public Safety Broadband Network (PSBN) Temporary National Coordination Office (TNCO), includes recommendations for the development of an interoperable PSBN for Canada that meets the needs of the public safety community.
  • The Government of Canada is committed to supporting this transition in a manner that benefits public safety outcomes and the safety of all Canadians. Public Safety Canada will continue to work with stakeholders, in collaboration with Innovation, Science and Economic Development Canada (ISED), to support the advancement of a PSBN.
  • In 2012, ISED issued the first spectrum decision in support of Public Safety Broadband requirements, with 10 MHz of 700 MHz broadband designated for public safety use. An additional 10 MHz was designated in a subsequent ISED decision in 2017.

Competition policy reform

Key Messages:

  • A competitive economy is a fair, growing, and innovative economy.
  • Amendments recently proposed to the Competition Act are a preliminary phase in modernizing the competition regime.
  • The Government of Canada intends to undertake a broader, public review of competition policy, and potentially introduce further reforms.
  • Through this process, the government is helping to create the kind of marketplace that will allow Canada’s economy to innovate and grow.

Supplementary Messages:

  • The recent legislative amendments to the Competition Act have helped address shortcomings in the Act and moved Canada to be more in line with international best practices.
  • The 2022 Budget indicated that the government will continue to consult broadly on the role and functioning of the Competition Act and its enforcement regime, as first signalled by Minister Champagne in February of that year.
  • Budget 2021 provided $96 million over five years, starting in 2021-22, and $27.5 million ongoing, to enhance the Competition Bureau’s enforcement capacity and ensure it is equipped with the necessary digital tools for today’s economy.

Background:

The Competition Act is a federal law governing most business conduct in Canada. Its purpose is to maintain and encourage competition, in order to provide consumers with competitive prices and product choices, among other things. The Commissioner of Competition heads the Competition Bureau and is responsible for the administration and enforcement of the Competition Act.

The Competition Act contains civil and criminal provisions that allow the Commissioner of Competition to review business conduct and mergers that may harm competition and consumers. The commissioner conducts investigations and, where necessary, takes cases before the Competition Tribunal or the courts to be adjudicated. The commissioner also carries out non-enforcement functions, such as advocacy for greater competition both within and outside of government, as well as international collaboration, both bilaterally and within multilateral fora.

In light of the significant changes that the Canadian economy has undergone with the global digital transformation and the rise of data-amassing “Big Tech” giants, questions have arisen as to the adequacy of the current legal framework.

On February 7, 2022, the Minister announced a commitment to pursuing potential changes to the Competition Act to make targeted improvements, broadening the Bureau’s scope of activity, fixing loopholes and adjusting maximum penalties to better account for the power of today’s major actors. This came to fruition with the Budget Implementation Act, 2022, No. 1, which included several key reforms to modernize the law and align it more closely with international norms. These included, among others: reformulating maximum penalties; prohibiting wage-fixing and no-poach agreements between employers; clarifying that incomplete price disclosure is a deceptive marketing practice; and allowing private access to the Competition Tribunal for those impacted by abuse of dominance.

The government has signalled a broader review of the law still to come, in accordance with Minister Champagne’s mandate letter and Budget 2022. Such an examination will afford stakeholders the opportunity to make their voices heard on a wide array of competition policy topics.

Canadian Radio-Television and Telecommunications Commission (CRTC) policy direction

Key Messages:

Supplementary Messages:

Policy Direction

  • The new policy direction supports the government’s efforts to ensure that telecommunications services are innovative, competitive and, most crucially, affordable.
  • The new policy direction provides specific instructions to the Canadian Radio-television and Telecommunications Commission (CRTC) to enhance and improve wholesale Internet access and competition, along with giving the CRTC improved support to better regulate going forward.
  • The government is also providing the CRTC with clearer direction on a number of important matters, including measures to support wireless competition, improve consumer rights, speed up service deployment and universal access, and build better regulations for a world where telecommunications are essential.

Wholesale Internet Rates

  • The government has heard from wholesale-based competitors that it is difficult for them to compete.
  • The proposed policy direction demonstrates a firm commitment to an effective and sustainable wholesale regulatory framework. It also instructs the CRTC to be timelier and more proactive.
  • Over the medium- to long-term, the government expects the policy direction to have positive effects for competition. The CRTC is monitoring the market and has the power to intervene if necessary to ensure the market remains competitive.

Background:

The new proposed policy direction to the CRTC aims to:

Enhance wholesale Internet access and competition for more affordable

Internet - The proposed policy direction will require large companies to continue to give access to competitors at regulated rates and take action to have more timely and improved wholesale rates available. It will also direct the CRTC not to phase out the existing model for wholesale access by third-party competitors and instead preserve and strengthen it in conjunction with the introduction of a new access model that it is planning to introduce. Furthermore, it will direct the CRTC to ensure that wholesale Internet access is available evenly across the market, including on fibre-to-the-home networks, and to require large companies to make the speeds that Canadians are demanding available to competitors.

Increase mobile wireless competition for more affordable cellphone plans - The proposed policy direction will direct the CRTC to improve its hybrid mobile virtual network operator (MVNO) model as it is being implemented over the coming years. The government is prepared to move to a full MVNO model, if needed, to support competition in the sector.

Improve consumer rights so Canadians can make better-informed choices - The proposed policy direction will require the CRTC to implement new measures to address unacceptable sales practices and improve transparency and clarity of service pricing, making it easier and more affordable for consumers to change or cancel services. Furthermore, it will require service providers to implement mandatory broadband testing so Canadians will know that the service they’re getting is what they’re paying for.  The policy direction will also direct the CRTC to improve accessibility of telecommunications services for Canadians with disabilities and to strengthen the Commission for Complaints for Telecom-television Services (CCTS). The CRTC will also be required to take steps to raise the public awareness of the CCTS and its powers to resolve disputes for consumers.

Speed up service deployment and universal access - The proposed policy direction will require the CRTC to improve access to telephone poles and similar infrastructure so service providers can deploy new services more quickly and continue implementing and adjusting its Broadband Fund to meet connectivity needs across the country in coordination with other programs.

Build better regulations - The proposed policy direction will require the CRTC to use the tools available to gather the necessary information to make sound decisions while being more proactive in strategic planning and market monitoring. Furthermore, it will direct the CRTC to ensure that its regulations are efficient and proportionate to their purpose, balancing economic regulation with competition and investment considerations.

Wholesale Internet Rates - The Governor in Council has acknowledged concerns about competition in the Internet services market and has reiterated a commitment to a wholesale services framework that achieves its objectives, including sustainable competition. Wholesale regulation is an important means to promote competition in the Internet market and put downward pressure on prices.

The rates that incumbent telecommunications service providers charge wholesale-based Internet service providers make up an important portion of the costs associated with offering services; therefore, lower wholesale rates can help lower prices for Canadians. These rates also impact forward-looking investment decisions for wholesale-based service providers. At the same time, facilities-based service providers make important investments in supporting the maintenance and quality of Canada’s network infrastructure. This helps ensure that Canadians have access to high-quality, reliable service, and wholesale rates can affect their incentives to make these investments. Therefore, getting the wholesale framework and rates right is essential.

The decision to decline to vary, rescind or refer back for reconsideration of the CRTC’s May 2021 decision will avoid putting in place rates that were not well-balanced and were based on errors.

Timelines and next steps - The proposed policy direction was posted in the Canada Gazette, Part 1 along with supporting documents including the Regulatory Impact Analysis Statement. Public and stakeholder comments concerning the proposed order were accepted for a period of 45 days which ended on July 19, 2022. All comments received will be posted on ISED's Spectrum Management and telecommunications website and are being analyzed by officials. The policy direction has been tabled in Parliament and 40 sitting days must elapse before it can be made final (earliest day possible projected to be October 27).

Telecom pricing

Key Messages:

  • Canadians rely on telecommunications services for work, school, finances and health care – making access to high quality and affordable wireless services essential.
  • The Government of Canada has been clear that greater affordability, competition and innovation in the Canadian telecommunications sector are important.
  • That is why the government has introduced measures to make wireless services more affordable, including spectrum policies that promote competition and a new policy direction to the CRTC.
  • The government continues to build on the progress made to promote competition and to further reduce prices.

Supplementary Messages:

  • Canadians need access to high-quality Internet services at affordable prices.
  • That’s why the government has introduced measures to make telecom services more affordable, such as the new proposed policy direction to the CRTC published in May 2022.
  • The government’s new proposed policy direction to the CRTC would require the Commission to put in place new rules to improve competition and advance consumer rights, leading to lower prices and better telecommunications services for Canadian consumers.

Update:

Wireless Pricing

The government’s 25% price reduction benchmark was announced in March 2020. The quarterly results published on January 28, 2022, demonstrated that the price reduction target was met ahead of the March 2022 deadline.

Wireless prices have generally declined. The 2021 Price Comparison Study of Telecom Services, commissioned by ISED, shows continued wireless price declines at all levels, with some plans as much as 22% lower compared to 2020. This builds on reductions as high as 31% in the previous year.

Spectrum Matters

ISED has taken successive actions through spectrum licensing to encourage competition. Most recently, on June 30, 2022, the government published rules for the 3800-Megahertz (MHz) auction, which include implementing a cross-band cap that will effectively reserve a total of 150 MHz across both the 3500 and 3800 MHz bands for smaller competitors. These rules build on those used in the 3500 MHz auction in 2021, which enabled small and regional providers to increase their total spectrum holdings by over 50%. The 3800 MHz auction will take place in 2023. 

Canadian Radio‑television and Telecommunications Commission (CRTC)

On May 26, 2022, the government announced a proposed new policy direction to the CRTC on a renewed approach to telecommunications policy. The new policy direction provides specific instructions to the CRTC to enhance and improve wholesale Internet access and competition, along with giving it improved support to better regulate going forward.

The government is also providing the CRTC with clearer direction on a number of important matters, including measures to support wireless competition, improve consumer rights, speed up service deployment and universal access, and build better regulations for a world where telecommunications are essential.

Rogers Communications acquisition of Shaw communications

Key Messages:

  • The Government of Canada has been clear that greater affordability, competition, and innovation in the Canadian telecommunications sector are important.
  • To protect Canadian consumers, the Competition Bureau has taken steps to block Rogers’ proposed acquisition of Shaw. 
  • The government has indicated that it will not permit the wholesale transfer of Shaw’s wireless licences to Rogers, as it is incompatible with the government’s policies for spectrum and mobile service competition.

Supplementary Messages:

  • The Government of Canada is aware that the Competition Bureau has challenged the merger by requesting an order from the Competition Tribunal to prevent it from proceeding until the Bureau’s challenge is heard and decided by the Competition Tribunal.
  • As the Competition Bureau is an independent agency, it would be inappropriate to comment further.
  • Regarding the potential transfer or Shaw’s licences to Quebecor, any such proposal would be subject to a rigorous review to ensure it was compatible with the government’s policies for spectrum and mobile service competition.
  • ISED will review the transfer of any spectrum licences associated with the proposed transaction using the Spectrum Licence Transfer Framework.

Background:

Acquisition Terms

On March 15, 2021, Rogers Communications Inc. announced the proposed acquisition of Shaw Communications Inc. for approximately $20 billion. Rogers would also assume about $6 billion in Shaw debt.

Shaw Overview

Shaw Communications Inc. is a Western telecommunications company providing telephone, Internet, television, and mobile services. Through its subsidiary Freedom Mobile, Shaw provides mobile services in British Columbia, Alberta, and Ontario. Shaw’s new wireless brand, Shaw Mobile, also wireless services in British Columbia and Alberta. Shaw is the main cable company in BC and Alberta. It also has cable systems in Saskatchewan, Manitoba, and Northern Ontario.

Rogers Overview

Rogers Communications Inc. provides telephone, Internet, television, and mobile services. Rogers is the largest wireless provider in Canada, offering wireless services under the Rogers, Fido, Mobilicity, Chatr, and Cityfone brands. Rogers has cable operations in Ontario, New Brunswick, and Newfoundland and Labrador.

Federal Review

On March 24, 2022, the CRTC approved, with modifications and the fulfilment of specific conditions, an application by Rogers, on behalf of Shaw, for authority to transfer the effective control of the broadcasting undertakings licensed to Shaw or its subsidiaries to Rogers or its subsidiaries.

On May 9, 2022, the Competition Bureau sought to block Rogers’ proposed $26 billion acquisition of Shaw. The Bureau challenged the merger by requesting an order from the Competition Tribunal to prevent it from proceeding. As a proposed remedy, the parties announced in June 2022 that Rogers and Shaw plan to sell Freedom Mobile to Quebecor Inc. for $2.85B.

Rogers, Shaw, and the Competition Bureau agreed to undertake mediation on July 4 and 5, 2022. The mediation was unsuccessful. There will be another opportunity for mediation in October 2022; should it be unsuccessful, the case is expected to go to a trial before the Competition Tribunal in November 2022, with a verdict potentially by the end of the calendar year.

Securing Canadians telecommunications system

Key Messages:

  • The Government of Canada is ensuring the long-term security of our telecommunications infrastructure.
  • The government intends to prohibit the inclusion of Huawei and ZTE products and services in Canada’s telecommunications systems.
  • This follows a thorough review by our independent security agencies and in consultation with our closest allies.
  • Telecommunications companies in Canada will not be permitted in their networks products or services that put our national security at risk. Providers that already have this equipment installed will be required to cease its use and remove it.

Supplementary Messages:

  • The government will always protect the safety and security of Canadians and will take any actions necessary to safeguard our telecommunications infrastructure.
  • The government intends to implement these measures to protect Canada’s telecommunications networks in consultation with industry.

Update:

  • Canada has been able to mitigate cyber security risk in 3G and 4G networks through a collaborative risk mitigation framework, the Canadian Security Establishment’s Security Review Program. The program will evolve to mitigate security risks in 5G networks and the telecommunications system more broadly, in collaboration with industry.
  • The Government of Canada undertook an in-depth 5G Security Examination. It found that while 5G technology will bring significant benefits and economic opportunities, it will also introduce new security concerns that malicious actors could exploit.
  • The government intends to implement the following actions, following consultation with industry:
    • The use of new 5G equipment and managed services from Huawei and ZTE will be prohibited, and existing 5G equipment and managed services must be removed or terminated by June 28, 2024.
    • Any use of new 4G equipment and managed services from Huawei and ZTE will be prohibited, and any existing 4G equipment and managed services must be removed or terminated by December 31, 2027.
    • The government expects that telecommunications service providers will cease procurement of new 4G or 5G equipment and associated services by September 1, 2022.
    • The government further intends to impose restrictions on Gigabit Passive Optical Network (GPON) equipment used in fibre-optic networks.
    • During these transition periods, telecommunications service providers that use this equipment and managed services would be required to comply with any assurance requirements prescribed by the government, building from the Communications Security Establishment’s Security Review Program.
  • These measures will be implemented as part of a new telecommunications security framework, which includes amendments to the Telecommunications Act to ensure that promoting the security and protection of our telecommunications system is an overriding objective of Canada’s telecommunications policy.
  • The amendments will include mechanisms to prohibit the use of equipment and services from designated suppliers where necessary to protect Canada’s telecommunications system.

Rural mobile coverage

Key Messages:

  • Mobile connectivity is important to Canadians regardless of where they live, work, and travel. While almost all Canadians have access to mobile coverage at home, gaps persist on First Nations reserves and along major highways and roads.
  • The Government of Canada is taking action to address this issue with $50 million set aside under the Universal Broadband Fund (UBF) for mobile Internet projects that primarily benefit Indigenous peoples.
  • Under the UBF, we have announced a project to provide complete mobile connectivity along BC’s Highway of Tears. This project fulfills a key recommendation of the National Inquiry into Missing and Murdered Indigenous Woman and Girls report.
  • The Government of Canada is also investing in mobile infrastructure through the Canadian Radio-television and Telecommunications Commission (CRTC) Broadband Fund and the Connect to Innovate program (CTI).

Supplementary Messages:

  • In addition to the Highway of Tears announcement, the government has also announced a project in the community of Manawan, Quebec to provide mobile connectivity along 10 km of road.
  • The government continues to assess mobile applications submitted to the UBF and looks forward to making announcements on selected projects very soon.

Background:

In 2019, the government committed through Canada's Connectivity Strategy to connect every Canadian to affordable, high-speed Internet no matter where they live, and to improve mobile cellular access from coast to coast to coast.

The government is supporting the development of mobile infrastructure through the following programs:

  • The CRTC’s Broadband Fund includes funding to support projects that build or upgrade access and infrastructure, for both fixed and mobile wireless broadband, in underserved areas.
  • The Connect to Innovate program has projects focused on supporting new backbone infrastructure to help service providers support improved speeds and service quality for mobile wireless users.
  • The Universal Broadband Fund has set aside $50 million for mobile projects that primarily benefit Indigenous peoples, including projects along highways and roads where mobile connectivity is lacking.

The CRTC Communications Market Report (CMR) indicates the following mobile coverage across Canada as of the end of 2020:

  • Canada overall: 99.7% covered (109,700 people without coverage)
  • Rural: 98.5% covered (100,900 people without coverage)
  • Indigenous: 90.5% covered (36,100 people without coverage)
  • Major roads and highways: 88.5% covered (13,137 km without coverage)

C-26: An Act respecting cyber security, amending the telecommunications Act

Key Messages:

  • The Government of Canada takes the security of the Canada’s telecommunications system very seriously.
  • That is why the government has introduced Bill C-26, An Act Respecting Cyber Security (ARCS), which would establish new authorities to promote the cyber security of Canada’s critical infrastructure including telecom networks.
  • The bill aligns with actions taken by Canada’s Five Eyes partners and will enable Canada to take strong action against all threats to its telecommunications networks be they natural or human in origin.
  • Once passed, the government will be able to direct telecommunication service providers to improve their security to better defend against human errors, espionage, natural disasters and more.

Supplementary Messages:

  • Canada’s telecommunication system underpins all of the country’s critical infrastructure and must be resilient.
  • ARCS is part of the government’s commitment to improving cyber security across Canada and will help protect national security and the public safety of Canadians.

Update:

  • On June 14th, 2022, the government tabled an Act Respecting Cyber Security (ARCS), which is comprised of two parts.
  • Part I would amend the Telecommunications Act (TA) to establish new authorities to enable the government to take action to promote the security of the Canadian telecommunications system, which could include prohibiting Telecommunication Service Providers (TSPs) from deploying services and equipment from high-risk suppliers and to address various vulnerabilities. The TA is under the mandate of the Minister of Innovation, Science and Industry.
  • Part I of ARCS would:
    • add “to promote the security of the Canadian telecommunications system” as an objective of the TA.
    • authorize the Governor in Council to impose prohibitions and requirements on TSPs in regard to the use of products and services from high-risk suppliers; and
    • allow for the Minister of ISI to specify administrative elements related to prohibitions and requirements, including conditions of service; provision of information such as network design, implementation of TPs’ own internal security plans and directing improvements as needed.
  • To promote compliance with orders and regulations made by the Governor in Council and the Minister of ISI, the TA would be amended to create an administrative monetary penalty scheme.
  • Part II of ARCS would establish the CCSPA, led by the Minister of Public Safety. It would:
    • enable the designation of certain cyber services and systems in the finance, telecommunications, energy and transportation sectors as vital to national security and public safety; and
    • implement a regulatory framework and directions to strengthen baseline cyber security for designated services and systems.
  • Designated operators would be required to establish a Cyber Security Program that documents how they will ensure the protection and resilience of their critical cyber systems. It would also require that reasonable measures be put in place to detect cyber security incidents and to minimize the impact of such incidents on critical cyber systems.
  • Designated operators would be required to report cyber security incidents affecting or having the potential to affect their critical cyber systems to the Canadian Centre for Cyber Security for review. A threshold defining this reporting obligation would be set in regulations.
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