By Mary-Claire Ball (University of Toronto) and Max Karpinski (University of Toronto)
When ChatGPT launched publicly in November 2022, it didn’t just spark headlines, it marked a turning point. Artificial intelligence (AI) and large language models (LLMs) moved from niche research tools to everyday technologies, changing how people work, learn and create. For universities, this shift has been especially profound, reshaping everything from administrative processes to teaching and research.
As part of the HEQCO Consortium on AI, researchers from the University of Toronto, the University of Western Ontario and McMaster University are leading a cross-institutional study of Ontario universities. Their goal: to identify promising practices for the safe and ethical use of AI, and to prepare universities for the ripple effects of evolving government policies and rapid advances in AI technologies.
Living Principles in a Fast-moving Field
AI moves quickly, and so do conversations about how to use it responsibly. A review of principles from tech companies, governments and educational organizations shows a growing consensus: AI policies must be flexible, responsive and treated as living documents. For Ontario universities, this means recognizing that any strategy must adapt to ongoing technological change and new challenges as they arise.
The word that comes up most often across these principles is responsibility. That includes addressing risks like safety, privacy and security, while also committing to transparency, fairness and accountability.
What Governments Are Saying
We see this language reflected in recent Canadian policy documents:
- Federal Guidance: In 2023, the Canadian government released its Guide on the Use of Generative Artificial Intelligence for federal institutions. The guide draws on the Treasury Board of Canada Secretariat’s FASTER framework — Fair, Accountable, Secure, Transparent, Educated and Relevant.
- Ontario’s Directive: Ontario’s Responsible Use of AI Directive echoes similar principles, focusing on responsibility, accountability and transparency.
- United Nations Educational, Scientific and Cultural Organization’s (UNESCO) Recommendation: Both federal and provincial guidelines align with UNESCO’s Recommendation on the Ethics of Artificial Intelligence, the first-ever global standard on AI ethics. This recommendation foregrounds the protection of human rights and dignity, emphasizing transparency, fairness and the necessity of human oversight.
For universities, these frameworks offer a foundation for creating policies that both align with global standards and reflect the specific values of higher education.
The Shifting Legal Landscape
The regulatory picture is still in flux. The federal Artificial Intelligence and Data Act (AIDA) — introduced in 2022 as part of Bill C-27 — has been tabled indefinitely with Parliament’s prorogation in January 2025. AIDA outlined a “risk-based approach” consistent with international norms. But even as its framework may shape future policy, Prime Minister Mark Carney and his newly appointed Minister of Artificial Intelligence and Digital Innovation, Evan Solomon, could pursue a different path and propose entirely new legislation.
Meanwhile, Ontario has already moved forward with Bill 194, the Strengthening Cyber Security and Building Trust in the Public Sector Act, which came into effect on July 1, 2025. It aligns with the UNESCO recommendation referenced above. Bill 194 also amends Ontario’s Freedom of Information and Protection of Privacy Act (FIPPA), requiring public institutions (including universities) to:
- disclose publicly when they use AI systems;
- manage and mitigate known risks; and
- establish clear accountability frameworks.
For universities in Ontario, compliance with Bill 194 and FIPPA is now a baseline requirement in any AI strategy.
Balancing Policy with University Values
Legal requirements and ethical principles are only part of the story. Universities must also ensure that their AI responses reflect academic values — integrity, fairness, accessibility and the pursuit of knowledge. Across Ontario, many institutions have already prioritized policies around teaching and learning, given the risks AI poses to academic integrity.
Possible approaches include:
- redesigning curriculum to include AI literacy and ethics;
- developing standards or guidelines for the ethical use of AI in research;
- setting clear expectations for how students can and cannot use AI in coursework; and
- ensuring equitable access to AI tools for students, staff and faculty.
However, these are complex challenges, and no single university can navigate them alone. A coordinated approach will help institutions adapt faster, share resources and uphold shared values across the sector.
Next Steps: Collaboration and a Summit
To chart a path forward, the HEQCO Consortium on AI research team is gathering insights through interviews with university leaders in Ontario and scanning existing institutional responses to AI. This work will culminate in an AI Summit hosted at the University of Toronto this fall.
The summit will bring together leaders from across Ontario universities to:
- share successes and challenges;
- compare approaches to AI policy;
- discuss compliance with any new legislation; and
- explore how to integrate AI responsibly into teaching, research and administration.
Meeting the Moment
AI is reshaping higher education in real time. For Ontario universities, this shift brings both opportunities and challenges, and the choices they make today will influence how AI aligns with and supports their academic missions. By working together and remaining open to different approaches, Ontario universities can prepare for a range of possibilities, whether that means embracing new tools, setting boundaries around their use or exploring alternatives. The AI Summit at the University of Toronto will provide a space for these conversations, inviting leaders to exchange ideas, share concerns and imagine together what the future of higher education might look like in an AI-influenced world.
In addition to the U of T AI Summit, HEQCO is hosting their tenth annual conference, ReimaginEd: Shaping the Future of Ontario PSE, on November 7, 2025. Members of this project team, along with colleagues from other Ontario colleges and universities, will be participating. Register before October 17 to save $25 on your ticket price.