Information Commissioner's Report Reveals ArriveCAN Investigation Exposes Digital Record-Keeping Challenges in Public Service

Canada's Information Commissioner has delivered a stark warning to Parliament: the government's transparency laws are failing to keep up with how public servants actually work. Caroline Maynard tabled her 9th Annual Report on June 16, 2026, capping a multi-year investigation into the Canada Border Services Agency (CBSA) and the ArriveCAN app — a pandemic-era project that ballooned to an estimated $59.5 million and became a symbol of federal mismanagement. National Post reported the findings.
The investigation found no criminal offence under the Access to Information Act. But Maynard called ArriveCAN a "cautionary tale" — proof that emergency conditions, poor record-keeping, and unmonitored digital tools can quietly gut the public's right to know.
ArriveCAN launched on April 29, 2020, as an emergency COVID-19 border tool. It became mandatory for all travelers entering Canada from November 2020 to October 2022. The app went through 177 different versions over three years. When the Auditor General Karen Hogan reviewed it in February 2024, she found the record-keeping was so poor that the final cost could not even be confirmed, according to The Sudbury Star.
The government used existing contracts to skip competitive bidding. The main contractor, GC Strategies, received $100 million in total federal contracts since 2011. Its two owners, Kristian Firth and Darren Anthony, were recently banned from federal contracting for seven years. A glitch in the app also sent 10,200 travelers incorrect quarantine orders, according to Fort McMurray Today.
The core problem Maynard identified was simple: CBSA staff made key decisions on Slack and Microsoft Teams. Those platforms were never properly linked to the agency's record-keeping systems. The messages were not saved. That means the paper trail — which access to information law depends on — never existed, according to Pembroke Observer.
Current law requires proof of intent to destroy records before an offence is triggered. Because the records were never created in the first place, no offence occurred. Maynard argued this makes the law "functionally toothless" in a digital-first workplace. She said the shift to remote and hybrid work has made the problem much worse, according to Edmonton Examiner.
Maynard is pushing Parliament to modernize the Access to Information Act. Her key ask: a mandatory "duty to document." This would legally require public servants to create records of their decisions — no matter which platform they use. Right now, no such obligation exists, according to Clinton News Record.
The government did take some action earlier. In May 2024, it set up the Office of Supplier Integrity and Compliance to replace an older oversight regime and expand grounds for banning bad actors. But critics argue that procurement fixes alone will not solve a deeper culture problem. As of 2024–25, 79% of all access to information requests are submitted online — yet the laws governing those requests were written for a paper world, according to Ontario Farmer.
CBSA defenders argued the app "saved lives" and was an "essential tool" built under extreme pressure. They say the lack of documentation was an unavoidable side effect of a public health emergency — not negligence. The government has maintained that pandemic speed required flexibility, according to County Market.
Auditor General Hogan and Commissioner Maynard both pushed back. They argued that "emergency" is too often used to shield incompetence. Hogan's 2024 report said CBSA "repeatedly failed to follow good management practices." A follow-up report in June 2025 showed the rot extended well beyond one app. The CBSA president acknowledged a "pattern of persistent collaboration" between officials and contractors that bypassed established rules, according to Ontario Farmer.
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