Toward Actionable Policy for the Use of AI in Canada’s Housing Crisis

Digital Policy Hub Working Paper

August 28, 2025

Most artificial intelligence (AI) governance guidance in Canada focuses on high-level, principle-based approaches, emphasizing “responsible,” “safe” and “ethical” AI. However, these approaches leave governance gaps in many sectors, including housing. As the second part of a two-part working paper series, this paper offers five policy recommendations to close this gap and mitigate AI-related harm in housing:

  • Establish a justification requirement for federal entities (and others that benefit from federal funding for housing) that are looking to use AI in the context of shelter service and housing provision.
  • Mandate human rights impact assessments as a condition of government funding for organizations that produce or use AI in homelessness management, either as a product or in operations.
  • Do not mandate the use of AI in homelessness management as a condition for government funding.
  • Prohibit the use of facial recognition technologies in residential areas.
  • Require both in-person and online hearings be made available for landlord-tenant dispute hearings.

The paper then ties these AI- and data-focused recommendations to two broader housing policy suggestions: the promotion of community land and data trusts and community-led response.

About the Author

Nathalie DiBerardino is a former Digital Policy Hub master’s fellow and Western University philosophy M.A. graduate, as well as an incoming Responsible AI Technology Consultant at EY Canada. At the Digital Policy Hub, Nathalie examined the role of data and artificial intelligence in Canada’s housing crisis.