MDR Strategy Group’s Daniel Roukema in conversation with New Zealand Deputy Prime Minister David Seymour
The Regulator | Page 4
Advancing dental technology in Canada through national collaboration
Regulators Gather for Meeting on AI and Regulation | Page 6
Reflecting on the 2026 AI in Regulation Conference
The Registrant | Page 18
Guiding AI into clinical practice
16, APRIL 2026
There is something fitting about this issue arriving later than planned.
Regulation, like the environments it operates within, rarely moves in straight lines. It responds, adapts, recalibrates. And over the past several months, that reality has been on full display.
Since our last issue, the global regulatory community has been in motion.
In December, many of us gathered in Wellington, New Zealand, for the Council on Licensure, Enforcement and Regulation’s International congress, a setting that felt both distant and deeply connected. The Congress brought together regulatory leaders from around the world to explore governance, accountability, emerging technologies, and the evolving expectations placed on our institutions. It was not a conference built around presentations alone, but one grounded in dialogue, challenge, and shared problem-solving.
It was in Wellington that I had the opportunity for a private meeting with the country’s deputy prime minister and minister of regulation. That conversation, and my reflections on it, form the cover story of this issue. It was a discussion that did not seek easy alignment, but something more valuable: a clearer understanding of how different jurisdictions are approaching the same fundamental questions about the role, limits, and future of regulation. We did not come to the same conclusions.
But we left with a deeper appreciation of what it takes to have those conversations in good faith. And in today’s environment, that may be one of the most important outcomes we can hope for.
Two months later, in February, we hosted the AI in Regulation Conference in Toronto. More than 130 senior regulatory leaders came together not just to learn about artificial intelligence, but to begin grappling with what it means to govern it responsibly. The conversations were practical, grounded, and, at times, uncomfortable. As they should be. AI is not a future consideration for regulators. It is a present reality, one that is already reshaping investigations, decision-making, and public expectations.
What became clear across both Wellington and Toronto is this: the questions facing regulators are no longer technical alone. They are institutional. They are cultural. And increasingly, they are public. Across jurisdictions, we are seeing the same pressures emerge. Higher expectations for transparency. Greater scrutiny of decisions. A demand for systems that are not only efficient, but demonstrably fair, accessible, and grounded in the public interest.
This issue of The Registrar reflects those shifts.
It is a return, yes, after a longer pause than intended. But it is also a re-entry at a moment when the work of regulation is being tested, and in many ways, redefined.
As always, our goal is not to provide easy answers.
It is to create space for the conversations that lead to better ones.
Daniel Roukema
CEO, MDR Strategy Group Editor-in-Chief, The Registrar
Journalists and Contributors
Adam Beaumont
Collette Deschenes
Melissa Peneycad
Grant Pink
Daniel Roukema
The Regulator
Expanding access to dental technology through national collaboration
Events
From awareness to action at the 2026 AI in Regulation Conference
Cover Story
Across the Divide: A Conversation with New Zealand Deputy Prime Minister David Seymour
AI in Regulation
Shining a Light on Shadow AI in Regulatory Bodies
News Channel
Buried Under Regulatory Burden: When Licensing Frameworks Evolve
The Registrant
Guiding AI Into Clinical Practice
Guest Editorial – Dr Grant Pink and Adam Beaumont
Regulatory Posture: Describing It, Developing It, and Demonstrating It
By Registrar Staff
Across health care professions in Canada, regulators are increasingly exploring how to create pathways to licensure that recognize a broader range of experience. This includes individuals who have developed skills through international education, related professions or years of hands-on work, but who have not followed traditional education routes in Canada. Creating fair, consistent ways to assess their competence and support entry to practice is becoming an important part of strengthening the workforce while maintaining public protection.
In dental technology, this work is already underway as the Canadian Alliance of Dental Technology Regulators (CADTR), leads a national approach to how competence is assessed and recognized.
CADTR is the national federation of dental technology regulators in Canada, bringing together provincial regulators that license more than 1,800 registrants across the country. These regulators work together at a national level on matters that support the regulatory mandate of each provincial jurisdiction to protect the public interest.
Historically, each regulator administered its own credential assessment and licensure exam. This resulted in inconsistent registration practices across the country and, at times, applicants seeking entry through jurisdictions with fewer requirements.
To address these challenges, CADTR launched the Access to Dental Technology (ADT) project, a two-phase regulatory modernization initiative funded by the Government of Canada through
Employment and Social Development Canada’s Foreign Credential Recognition Program.
Through the ADT project, the alliance is strengthening how competence is defined, assessed and recognized across jurisdictions, supporting consistent standards for safe and competent practice. licensing law.
The initiative’s first phase, ADT I, established a formal and consistent pathway to meet the minimum entry-to-practice requirements for licensure. It introduced the National Essential Competencies for Dental Technology Practice in Canada (NEC) and the National Essential Entryto-Practise Competencies (NEETPC), shared benchmarks that now form the basis for licensure across the country.
It approved Canadian dental technology educational programs and created substantial equivalence pathways for applicants who had not graduated from one of those programs. The initiative also introduced standard, psychometrically valid and defensible licensure examinations, a single point of entry for pre-registration requirements, and accessible pre-arrival tools to help internationally educated professionals begin preparing before arriving in Canada.
For the first time, this work created a consistent national framework for the profession.
Despite the success of ADT I, there was a group that its framework still could not reach.
Due to the nature of dental laboratory work, many individuals develop dental technology skills over time through experiential learning. Dental laboratory associates often begin by observing workflows, supporting production and taking on progressively more complex tasks. Through this process, they build competencies aligned with dental technology practice.
These individuals have developed relevant competencies but have not had a clear pathway for those competencies to be formally assessed and recognized within existing approaches.
ADT II was initiated to address this gap by expanding how competence is recognized through a new pathway to licensure, the Prior Learning Assessment and Recognition (PLAR) pathway.
As the alliance explains, traditional credential assessment approaches primarily compare an applicant’s formal international education to approved Canadian programs. CADTR’s PLAR model, currently in a pilot phase, expands on this by recognizing that equivalent competencies may also be gained through experiential learning. It offers a flexible and accessible pathway by evaluating how an individual’s prior learning and practical experience align with established national benchmarks, while maintaining consistent standards for public protection.
Early response to the PLAR pilot signals clear demand for this new pathway into the profession. “We’ve seen a strong response to the PLAR pilot, achieving 50% of our target for expressions of interest. It’s not limited to today’s newcomers which tells us that there’s merit in this pathway for dental lab associates who were not able to enter the profession in the past,” the alliance said.
For many, this pathway offers a way to move toward becoming a licensed professional. As the alliance notes, applicants are proceeding through the PLAR pilot to gain formal recognition for the skills they have developed, opening the door to new opportunities for career advancement within the profession. They have approached the process with care, reflecting the significance of this opportunity.
While early response to the PLAR pilot highlights the need and demand for this new pathway, it also reflects the work required to bring it to life.
As the alliance noted, the work has come with challenges: “Dental technology is a relatively small profession in terms of registrants, so securing sufficient participation from subject matter experts within the profession, along with recruiting enough candidates for the pilot, has been a challenge. The ADT project has successfully achieved both. However, continued engagement and support from the profession are essential to sustain and build on this progress.”
Looking back on the project to date, the alliance points to the importance of early and ongoing engagement with members of the profession, educational programs and other system partners. Clear communication and education about the purpose and scope of the initiative are essential to building understanding and support.
A key part of that communication has been reinforcing what the PLAR model is, and what it is not. The alliance emphasizes that it is not intended to replace formal education. Instead, it provides an alternate pathway for individuals who have developed the required competencies through experiential or other forms of learning, while maintaining established standards for public protection.
The ADT project is, at its core, about inclusion, removing barriers and giving qualified candidates a fair chance to be recognized for what they know and what they can do.
It is a model that other regulators, in dental technology and beyond, are watching closely. The work of ADT continues, and participation from the profession remains essential. With a national foundation now in place, the pathway to recognition is more accessible than it has been before. More information is available on CADTR’s website. •
Toronto, February 2026
The AI in Regulation Conference, co-hosted by MDR Strategy Group and Objective Corporation, brought together more than 160 regulators, policymakers, governance leaders, and public-interest professionals from across Canada and internationally to examine how artificial intelligence is reshaping regulatory practice and public protection.
Held in Toronto on February 2-3, the conference combined training with cross-sector dialogue. Day one featured a fullday workshop on AI and regulatory governance for regulatory Board and Council members and senior leaders. Facilitated by Melissa Peneycad, director of public engagement and AI strategy at MDR Strategy Group and Bradley Chisholm, principal and founder of The Regulator’s Practice, the workshop focused on AI governance and Board oversight of AI, assessing risk to the public, determining appropriate uses of AI, and making informed decisions that align with regulators’ public-interest mandate and operational needs. That evening, attendees were treated to a keynote by Carol Anne Hilton, CEO of the Global Centre of Indigenomics challenged assumptions about neutrality in AI governance, noting it can limit regulators’ influence over systems that affect public outcomes.
Speakers emphasized that early decisions, including procurement, data selection and system design, play a critical role in shaping outcomes. In his keynote address, Dr. Fola Adeleke, executive director of the Global Center on AI Governance, highlighted the risks of errors in regulatory contexts, including unfair investigations or delayed services, underscoring the need for transparency and oversight.
Across both days, speakers returned to a shared point. AI is already influencing licensing, investigations and other regulatory decisions, and the choices regulators make now will shape how fairly and effectively those systems serve the public.
Photo credits: DA Photoraphy
At MDR Strategy Group’s two AI in Regulation conferences, held in Toronto in 2025 and 2026, one theme emerged repeatedly: AI is advancing quickly, and its implications for regulatory bodies are real and continue to evolve.
Many regulators are beginning to explore AI internally. Some are well on their way to enterprise-wide implementation. At the same time, the professionals they regulate are increasingly using these tools in practice. These shifts are reshaping the regulatory environment, introducing both exciting opportunities and new responsibilities for regulators at every level of the organization.
Different roles across a regulatory body require tailored support based on their responsibilities. Staff working in operational areas need practical guidance on appropriate use, privacy, documentation, and where human judgment must remain central. Leaders need to understand where AI may improve efficiency, where it may introduce risk, and what governance measures are needed to support responsible use. Executives need a strategic view of readiness, policy, and organizational implications. Board and council members need sufficient AI literacy to ask the right questions, exercise oversight and fiduciary responsibilities, and make decisions that align with the public interest.
Without role-specific AI training, understanding develops unevenly across the organization, leading to inconsistent practices, gaps in accountability, and missed opportunities to use AI effectively. With training, regulators are better positioned to govern AI responsibly, strengthen internal capacity, and respond to risks with confidence.
For regulators, AI training is no longer a professional development exercise. It’s part of good governance, sound risk management, and public protection.
To learn more about customized AI workshops and training programs for regulators, including role-specific sessions for staff, executives, and board/council members, contact Catherine Robar, director of strategic partnerships at catherine@mdrstrategy.ca
By Daniel Roukema, CEO, MDR Strategy Group
It was raining on Dec. 3, 2025, when I arrived at the Beehive, the executive wing of New Zealand’s parliament buildings, for a meeting with the country’s Deputy Prime Minister and Minister for Regulation, David Seymour. Wellington has a way of making weather part of the experience. The wind cuts sharply through the
downtown core, turning corners into gusts and steady steps into measured ones. Knowing about the conditions is one thing, experiencing them is another. As I made my way through security, there was a sense of anticipation, and a question lingering in the background: would the meeting ahead be smooth sailing, or was a storm brewing?
With me were two colleagues from MDR Strategy Group and a partner from New Zealand’s regulatory sector. We were escorted upstairs to a waiting area by Seymour’s office. The space was modest and functional, with the kind of understated formality typical of government offices.
As we waited, I glanced at my team. Melissa Peneycad, our director of public engagement and AI strategy, was reading the room, scanning for cues about tone and posture, assessing what kind of conversation we were about to enter. Collette Deschenes, our director of communications strategy, seemed to be taking in the moment from a different perspective, attentive to how the interview might unfold. Our New Zealand colleague sat with a quiet sense of pride, having helped broker a meeting that brought together a Canadian firm, an international publication on regulation, and a face-to-face meeting with a senior government leader who also serves as minister for regulation.
There was a brief pause before the door opened.
“So, which one of you is Daniel?”
I stood, introduced myself and the team to David Seymour, and we were invited into his office. He greeted us with a friendly, welcoming manner and a quiet confidence. Having seen him speak at a conference in Brisbane a few months earlier, I was struck by how different the setting felt in person. He carried himself with ease, engaging directly, but with the presence of someone who is thoughtful and deliberate.
After a brief exchange of pleasantries, we spoke about The Registrar magazine, Canada, and his previous work there. The tone was courteous and measured, setting the stage for a conversation that moved naturally into a more substantive discussion.
First elected in 2014, David Seymour is the leader of the ACT Party. He has built a reputation for advancing a distinct, and at times challenging, perspective on the role of government and regulation. His views are well known and often differ from those held by much of the regulatory community in New Zealand and internationally.
While our political ideologies are not aligned, I approached the meeting with a genuine interest in his perspectives and vision, and with respect for both the individual and the office he holds.
For an hour, we discussed regulation, governance and public policy. Seymour spoke with clarity, precision and a clear passion for philosophy, outlining his views in a structured and deliberate way. He took on questions and alternative viewpoints, often returning to first principles to explain how he approaches regulatory decisionmaking.
Our conversation remained measured and constructive throughout. It was a conversation grounded in discipline rather than performance, and in that sense, it stood apart from much of what defines public discourse today.
His approach to regulation is grounded in a philosophy that emphasizes individual agency, property rights and a constrained role for government. He has described regulation as a restriction on the use and exchange of property, undertaken in pursuit of a public objective, and has argued that such restrictions must be clearly justified.
That perspective was explored in more detail the following day, when Seymour addressed delegates at the eighth International Congress
on Professional and Occupational Regulation and Regulatory Research Day hosted by the Council on Licensure, Enforcement and Regulation (CLEAR).
Speaking to an audience of regulators, researchers and policy leaders, Seymour positioned himself as offering a challenge to conventional thinking. He described what he sees as a gap in how governments approach regulation, noting that while fiscal and monetary policy are subject to structured oversight, regulation has not been examined with the same level of discipline.
He pointed to the creation of New Zealand’s Ministry for Regulation and the introduction of the Regulatory Standards Act as steps intended to bring greater transparency and accountability to lawmaking.
Seymour said regulation, by its nature, imposes constraints, and those constraints should be subject to careful analysis. He argued that over time, regulatory systems can accumulate layers of rules and processes that increase complexity and cost without delivering proportional public benefit.
In illustrating this point, he referred to examples where similar projects today require significantly more approvals, consultants and compliance steps than in previous decades, raising questions about whether the additional regulatory activity has produced better outcomes.
His remarks also touched on the need to balance competing interests, including access to services, quality of outcomes and the broader economic impact of regulatory decisions.
For many regulators, particularly those working within professional and occupational frameworks, the primary focus remains on public protection, safety and trust. Regulatory systems are designed to ensure that individuals and communities can rely on competent, ethical and accountable services. From that standpoint, regulation is a safeguard, not a constraint.
Seymour’s views shift the focus toward economic impact and system efficiency, while drawing attention to how regulatory frameworks can, at times, create unintended barriers to access and innovation. These differences are substantive;
they reflect distinct ways of understanding the role of regulation in society. And yet, within those differences, there is also a point of connection.
In regulatory practice, there is an increasing focus on ensuring that systems remain relevant to the public they are intended to serve. This includes demonstrating value, improving accessibility and responding to changing expectations. It reflects a broader shift toward understanding regulation as a public-facing function that must maintain legitimacy and trust, rather than simply a system of rules.
I came to see that Seymour’s remarks, while grounded in a different philosophy, also speak to relevance.
His focus is on whether regulatory systems continue to justify their existence, deliver outcomes that outweigh their costs, and remain aligned with the broader public interest. While the language differs, the underlying question is similar: are these systems producing meaningful and relevant results for the people they affect?
While the approaches to regulation differ, the common denominator is the expectation that regulatory systems should have a clear and measurable public impact.
Reflecting on the exchange and his remarks to the international regulatory community, the following day, Seymour did not change my views on the importance of regulation as a tool for public protection. Those views remain grounded in the responsibility regulators hold to the public they serve.
However, what the experience did reinforce was the value of constructive engagement.
The ability to sit across from someone with a fundamentally different perspective, explore serious issues, and do so in a respectful and constructive way is not something to be taken for granted.
We did not come to the same conclusions. But we had the kind of conversation that makes better conclusions possible.
In today’s environment, that matters. I respect it. •
By Melissa Peneycad, director of public engagement and AI strategy, MDR Strategy Group
Across organizations, AI is being used more extensively than many leaders realize: for drafting and summarizing, scheduling, translation, search, meeting transcription, document review, analytics, and service delivery to registrants and the public. Some of this use comes through AI assistants such as ChatGPT. Some of it is embedded in widely used tools and platforms, including Microsoft 365, Adobe Acrobat, Zoom, Canva, CRM systems, and even browsers such as Chrome. Together, this poses a clear governance challenge as AI use expands rapidly and unevenly, often with limited visibility across the organization.
This is where shadow AI becomes a concern. Shadow AI refers to employees using AI tools, applications, or services without the organization’s approval, oversight, or knowledge. This also applies to commonly used software
platforms, such as those listed above, which may be approved at the time of purchase but are later updated with AI features that receive little to no additional review.
The implications are broader than they may seem. When an organization lacks visibility into how AI is being used, it may also lack visibility into where sensitive information is going, how AI outputs influence work, whether decisions are being shaped by unverifiable content, and who is accountable when something goes wrong. For regulators, those blind spots can affect confidentiality, quality, accountability, and the defensibility of decisions and processes, with corresponding implications for fairness, transparency, public trust, and legitimacy. The shadow AI problem is much bigger and more common than leaders may realize.
Gartner reported in late 2025 that 69 percent of organizations suspect or have evidence that employees are using prohibited public generative AI.[i] In 2026, Microsoft reported that 29 percent of employees have turned to unsanctioned AI agents, or AI tools designed to perform tasks with some degree of autonomy, for work tasks, even as only 47 percent of organizations have implemented dedicated security controls for generative AI.[ii]
Similarly, recent research conducted on behalf of cybersecurity firm BlackFog found that 49 percent of workers reported using AI tools without employer approval, often through free versions that may expose sensitive data.[iii] While these findings are not specific to the regulatory sector, they point to a broader workplace pattern in which AI use is outpacing organizational controls, and regulators should not assume they are exempt from the same dynamics.
One of the first mistakes organizations make is assuming that a policy prohibiting the use of AI for work will solve the problem. In practice, that approach often drives AI use further underground, reducing visibility rather than risk.
If leaders want to shine a light on shadow AI; they need to take a more deliberate approach.
The starting point is usually a baseline AI inventory. This does not need to be complex, but it should be structured: discovering and cataloging AI systems already in use, scanning for unsanctioned tools, and mapping existing AI assets. This means identifying what AI tools are being used, by whom, whether they are personal or organization-managed accounts, whether they are free, paid, or enterprise versions, what they are being used for, what information may be entered into them, and what privacy or data settings are enabled.
Self-reporting of AI use is rarely sufficient. Regulators can also use their own systems and records to identify how and where AI is used. Depending on the organization, this may include reviewing software licenses, enabled AI features, administrative dashboards, sign-on records, access logs, browser activity, and other indicators
that show which tools, functions, and interactions are active. These methods will not capture every form of personal or off-network AI use. That is why technical discovery works best when paired with clear expectations and an environment where employees feel safe speaking candidly about current use.
This also gives leadership an opportunity to understand whether and how staff need better support and where safer, organization-approved alternatives may be needed. A clear message from the CEO or Registrar that the purpose of the exercise is visibility, risk management, and responsible practice, rather than blame or shame, can make a meaningful difference.
Once an organization has a clearer picture of current AI use, it is in a much stronger position to decide what should be encouraged, restricted, approved, monitored, or prohibited. It can then move toward a more intentional framework that includes policy, staff guidance, approved use cases, training, review expectations, procurement decisions, and, where appropriate, investment in more secure or enterprise-grade tools.
For regulators, the task is to ensure that AI use does not outpace the controls needed to protect confidentiality, defensibility, risk management, and public trust.
The organizations best positioned to manage AI well will not be those that assume they have full visibility into how and where it is being used simply because no one has raised concerns. They will be the ones prepared to ask harder questions, dig deeper to uncover what is already in use, and create a responsible path forward. After all, you cannot govern what you have not yet identified. •
[i] Gartner (2025). “Gartner Identifies Critical GenAI Blind Spots That CIOs Must Urgently Address” [Press release]. See link
[ii] Microsoft (2025). “Cyber Pulse: an AI Security Report | Security Insider.” See link
[iii] BusinessWire (2026). “Shadow AI Threat Grows Inside Enterprises as BlackFog Research Finds 60% of Employees Would Take Risks to Meet Deadlines.” See link
By Registrar Staff
Regulation is not static. It reflects the priorities, risks and public expectations of its time. As markets evolve, statutory frameworks must occasionally be revisited to ensure they continue to serve the public interest.
In Oklahoma, a current legislative discussion has prompted reflection on the scope of funeral director licensure and the retail sale of caskets.
Candi Mentink and Todd Collard operate Caskets of Honor, a business that purchases caskets from wholesalers and applies customized vinyl wraps. Their work does not involve handling human remains, conducting funerals or providing embalming services. It is limited to the retail sale and aesthetic customization of burial containers.
Under Oklahoma law, selling caskets requires a funeral director license. That license involves mortuary science education, examinations, apprenticeship requirements and compliance with professional facility standards.
The licensing structure was established within a broader framework designed to protect consumers during one of life’s most vulnerable moments.
In response to an inquiry from The Registrar, Tyler Stiles, executive director of the Oklahoma Funeral Board, clarified the board’s position regarding proposed legislative change.
“Since Jan. 11, 2024, the Oklahoma Funeral Board has been neutral on the Senate Bill 559 allowing anyone to sell caskets to the public,” Stiles wrote. He noted that the proposal appears consistent with approaches adopted in many other states and emphasized that the board is not opposing the measure.
Stiles also explained the historical context of the current law. He said its purpose was to protect grieving consumers from potential overreaching sales tactics during emotionally vulnerable periods.
The board’s neutrality highlights an important governance principle. Licensing requirements are established by legislatures. Regulatory boards administer and enforce those statutes within their mandate. When lawmakers consider amendments, regulators ensure continuity of public protection and orderly implementation.
The discussion in Oklahoma does not question whether funeral services should be regulated. They should be. Funeral director licensure encompasses embalming, pathology, grief counseling and oversight of funeral services. These competencies are central to safe and ethical practice.
The narrower question is whether every activity adjacent to funeral services must fall within the same comprehensive license.
Across jurisdictions, regulators periodically review scope-of-practice boundaries. In some states, legislatures have chosen to separate casket sales from funeral director licensure. In others, the requirement remains integrated. These policy decisions reflect differing legislative judgments about consumer protection, market structure and regulatory design.
The Institute for Justice, a U.S.-based public interest law firm supporting Mentink and Collard’s legal challenge, argues that licensing requirements for casket sales should be directly tied to demonstrable risks to public health, safety or welfare.
In written responses to The Registrar the institute stated that required training and examinations should address a clearly identified public problem. It noted that most U.S. states permit third-party casket sales without funeral director licensure and suggested that general consumer protection laws provide safeguards for retail transactions.
The institute views the issue as one of ensuring that licensing requirements remain aligned with risk.
For regulatory leaders, the Oklahoma conversation illustrates a broader principle: effective regulation requires periodic reassessment.
Licensing is one of the most significant instruments available to regulators. It establishes standards, creates accountability and reinforces public trust. At the same time, regulatory legitimacy depends on ensuring that licensing requirements remain
proportionate and clearly connected to the risks they are designed to mitigate.
When legislatures review licensing statutes, regulators play a central role in informing those discussions and implementing any resulting changes. Their responsibility is stewardship. That includes maintaining strong consumer protection while adapting to evolving market realities.
The SB 559 presents Oklahoma lawmakers with a policy choice about whether retail casket sales should continue to require funeral director licensure or be addressed through alternative oversight mechanisms.
Whatever the outcome, the discussion reflects a normal and constructive feature of modern governance. Statutory frameworks are not immune to review. They are strengthened by it.
Across North America, regulatory bodies increasingly engage in structured scope reviews, sunset provisions and evidence-based policy analysis. These processes reinforce regulation by ensuring that frameworks remain current and risk-aligned.
The Oklahoma case is part of that broader pattern. It does not represent a rejection of regulation. It reflects an examination of how regulatory tools are applied and whether their scope remains appropriate.
For regulators observing from other jurisdictions, the case offers a reminder that public confidence rests on two pillars. The first is strong and consistent enforcement. The second is clarity of purpose. When licensing requirements are transparent, proportionate and clearly tied to risk, they command respect. When legislatures revisit statutory frameworks, regulators have an opportunity to reaffirm how professional oversight serves the public interest.
Sometimes a focused question about a single product can open a wider conversation about how regulation evolves.
That evolution, when guided carefully, strengthens the system rather than weakens it. •
Clinical counselor and AI ethicist Candice Alder on developing Canada’s first guidelines for the ethical integration of AI into clinical practice
By Registrar Staff
Candice Alder has spent more than two decades helping children, youth and families in British Columbia navigate some of life’s hardest realities.
From her early work in public education as a child and youth counselor to her child protection work in government and experience in family court settings, and now in private practice, Alder’s work has consistently centred on supporting vulnerable children, youth and families navigating complex systems.
A clinical counselor and psychotherapist, Alder began her career with the Surrey School District before moving into child protection and child and youth mental health with British Columbia’s Ministry of Children and Family Development. Reflecting on that period, she highlights how the work was demanding but formative.
“It shaped my understanding of care, accountability and professional responsibility,” she said.
While child protection is often viewed as enforcement-driven, Alder described the work as inherently therapeutic when approached through a clinical lens.
“When you knock on a family’s door and tell them there’s been a child protection report, fear is already in the room,” she said. “Everything you do after that depends on your ability to engage people with care, honesty and skill.”
Today, Alder brings that clinical lens and experience working with vulnerable populations to her work as an AI ethics and policy specialist focused on governance in high-risk, humanimpact domains.
She is co-founder and principal consultant at Synthetica, where she advises organizations on responsible AI governance, risk management and ethical integration in professional and humanservice environments. She also contributes to international AI governance and standards
initiatives and serves as an IEEE CertifAIed authorized assessor of emerging AI systems.
When she first glanced over her partner’s shoulder at an early beta version of what would become ChatGPT, she saw a technological turning point with profound implications for the people she serves.
“It was obvious right away that this wasn’t just another tool,” she said. “This was something that could reshape systems very quickly, often without the people affected understanding how or why decisions were being made.”
While she was impressed by the efficiency of early generative AI tools, she quickly became concerned about their broader implications. What concerned her most was how easily AI tools could be adopted by professionals without adequate training, oversight or ethical guardrails. In mental health, that risk is intensified by power imbalances and client vulnerability.
“This is a technological revolution on par with the printing press,” she said. “But unlike previous revolutions, we are dealing with systems that may one day direct their own development. That’s something humanity has never faced before.”
She began examining how AI could affect children, youth and older adults, particularly in contexts involving consent, mental health and dependency. She points to harms already emerging, including documented cases of emotionally vulnerable youth forming harmful relationships with AI chatbots.
“When AI enters human-serving professions, the risks don’t stay with the technology,” she said. “They land on the people we serve.”
In Canada, the absence of comprehensive AI legislation has left regulators trying to fit fast-moving technologies into existing ethical and practice frameworks. From Alder’s perspective, many organizations are relying on broad, high-level principles while registrants are left without clear, practice-level guidance on how AI
should be used responsibly. She sees this as a pivotal opportunity for regulatory bodies to shape how AI is integrated into professional practice, rather than simply responding to its use after the fact.
As president of the Board of Directors for the BC Association of Clinical Counsellors (BCACC), she is directly engaged in how the profession responds to the growing use of AI in clinical practice. Drawing on her AI ethics expertise and front-line clinical experience, she led the development of Canada’s first guidelines on the ethical integration of AI into clinical practice, released by BCACC in March 2025.
“With AI, you can’t expect clinicians to know what they don’t know,” she said. “The guidelines are meant to be a step-by-step roadmap so people can decide if AI is right for their practice, and if so, how to use it safely.”
Grounded in widely recognized ethical frameworks, including those developed by UNESCO and the OECD, the guidelines walk clinicians through issues such as informed consent, privacy, data storage and transparency. They aim to reflect both emerging international standards and the realities of clinical practice.
Alder noted that many clinicians are already using AI-based tools such as transcription services without understanding key details like privacy policies, where data centers are located, how data is handled or who can access it. She acknowledges that AI can ease the burden of clinical documentation but emphasizes that clients inherit the risks practitioners take.
“They deserve to know what’s happening with their information,” she said.
From Alder’s perspective, that expectation should not stop with clinicians. The same principles, she argues, need to apply to the regulators that are using AI in their own work and to set expectations for others.
She explains how that bar starts with regulators developing a minimum baseline understanding of how AI systems work, what data they rely on and where risks are. Even when external experts are involved, she said, boards and senior leaders still need enough literacy to ask informed questions and make defensible decisions.
She stresses that this is not just about future legislation or hypothetical systems. Many regulatory bodies are already experimenting with AI-powered tools to draft documents, summarize information or triage inquiries, sometimes using registrant or public data in the process.
“Every time you run information through an AI system, you’re making a decision about risk,” Alder said. “You need to know what you’re using, where the data goes and what your ethical obligations are.”
She expects that Canadian AI regulation, when it arrives, will likely adopt a risk-based approach similar to the European model, with heightened expectations for systems operating in high-risk, human-serving domains. Regulators that begin building AI literacy now, she said, will be better prepared to adapt as formal rules evolve and to support registrants through that transition.
In her view, the questions boards and councils should be asking are straightforward, even if the answers are complex.
How are we already using AI with registrant and public data? What internal competencies do we need to understand and oversee those tools? What clear, practical expectations will best support practitioners who are beginning to use AI in their work?
“No one has all the answers yet, and that’s OK,” she said. “What matters is that we’re asking thoughtful questions and keeping the public interest at the center.”
Keeping the public interest at the center reflects Alder’s longstanding dedication to supporting vulnerable children, youth and families across classrooms, courtrooms and years of clinical practice. She knows firsthand how the most vulnerable may never even know an AI system was involved in a decision that affects their lives and highlights how AI in regulated practice must be held to the same ethical standards as any other aspect of care.
“At the end of the day, children and families really are the fundamental units of society,” she said. •
“If AI is going to be part of the systems that shape their lives, then we have to be just as serious about competence, consent and accountability there as we are anywhere else.”
Guest editorial written by Dr. Grant Pink, Pracademic Advisor to the National Regulators Community of Practice (NRCoP) and Adam Beaumont, NRCoP National Committee member.
In our roles as regulatory advisors, educators, and academics, ‘regulatory posture’ is a topic that frequently presents during discussions. Despite the increasing frequency and intensity of these discussions ‘regulatory posture’ continues to prove to be a difficult concept for regulators to describe, develop, and demonstrate.
Republished with permission from the Australia and New Zealand School of Government (ANZOG).
Link to the original article
Regulatory posture – describing it
What is regulatory posture?
Most simply ‘regulatory posture is the approach or stance that a regulator adopts towards those it regulates’.[i] A regulatory posture requires a regulator to balance a range of primary, secondary, and tertiary tensions.[ii]
A regulator’s posture may have fixed, firm, and flexible elements. However, it is important to recognise that the general approach or perceived response applied by the regulator can be seen as projecting a defined or default regulatory posture. For example, the perception (or reality) is that the regulator:
• always defaults to education; or
• will always take enforcement action.
Regulatory posture – developing it
Why deliberately develop a regulatory posture?
If regulators do not intentionally develop a regulatory posture it is likely they will be attributed with or ascribed with one. Noting that the ones given to them by regulated entities, stakeholders, the wider community, and even in some instances by co- and peer- regulators, are almost always negatively framed.
For example, regulators may be described as:
• a toothless tiger – suggesting they have no real power or authority, or they may have powers but are unwilling to use them.
• acting like jackbooted enforcers – implying they are overly heavy-handed, not proportionate, or are wanting to be seen as taking action (regardless of the perceived or justifiable need).
• behaving like a windsock/pendulum –indicating they are unsure, overly reactive, or are acting in response to a past significant failure or event (as opposed to what’s in front of them).
• being a puppet – of a third party, i.e. government, industry, or interest group.
A regulator shared that a regulated entity had recently described them as now acting more like a ‘Watch Dog’, having previously been perceived very much as a ‘Lap Dog’.
Continuing with the dog analogy, and in a linear fashion, when asked to consider what the next
iteration could be described as. Their response was ‘Guard Dog’.
Panellists at a regulatory conference were specifically discussing communicating enforcement actions or prosecution outcomes, as a sub-set of regulatory communications.
Once again, continuing with the dog analogy, and still in a linear fashion, panellists were asked to consider what the next iteration could be described as. Their response was ‘Attack Dog’.[iii]
Where can regulatory posture be demonstrated?
For maximum impact, a regulatory posture should be actively and positively projected and explained. It should therefore be demonstrably evident, both directly and indirectly, in:
• documents – such as regulatory strategy, regulatory priorities, and regulatory policies;
• demeanour – of agency staff in terms of their regulatory identity, regulatory culture, and regulatory professionalism; and
• deliverables – such as achievement of regulatory outcomes, and maintenance of regulatory relationships.
Continually demonstrating an agency’s regulatory posture across, and beyond, the aspects outlined above has a mutually reinforcing/force multiplier effect.
How many regulatory postures is enough?
The less than helpful but accurate answer to this question is: enough, but no more than is necessary!
If a regulator attempts to arbitrarily apply a single regulatory posture across the depth and breadth of its regulatory activities and regulatory systems:
• it is the equivalent of trying to fit a square peg in a round hole or trying to eat every meal with a spoon; and
• it is highly likely that there will be unintended consequences, and the regulator will receive significant push back when other pressures are at play (think COVID, Global Financial Crises, major natural disasters, thin market dynamics in regional areas).
Equally, it is not possible nor appropriate for a regulator to develop highly (industry, sector, or regulated entity specific) individualised or customised regulatory postures. To do so moves us into discussions around Regulatory Statements of Expectation and Regulatory Statements of Intent.
If a regulator is projecting too many different types of regulatory postures across the depth and breadth of its regulatory activities and regulatory systems:
• it is the equivalent of trying to be everything to everyone and nothing to all of them simultaneously. This issue is compounded where regulatory culture is immature or fragile, and this can create different types of challenges around how the regulator applies regulatory discretion, makes choices, and regulatory decisions; and
• as above, it is highly likely that there will be unintended consequences, and the regulator will once again receive significant push back.
A regulator might benefit from developing a general regulatory posture. That is one that generally
reflects its posture and stance, across its various regulatory activities and regulatory systems.
Equally, it could be appropriate for a regulator to develop several sub-postures. These postures would sit beneath the general regulatory posture, and would enable the regulator to consider the primary, secondary, and tertiary tensions alluded to in the definition above.
This may be especially useful for those regulators that:
• have responsibility for administering multiple regulatory systems;
• are operating across different regulatory domains;[iv]
• engage with different regulated sectors and industries;
• are regulating in new, emerging or rapidly changing sectors; or
• involve different regulated commodities.
The consequences around regulatory posture (i.e. of either not having a regulatory posture or not having clearly defined sub-postures) compounds for those regulators that have regulated entities actively operating under multiple regulatory systems, and who may also be operating across different jurisdictions.
Let’s meet the entire pack
Thus far this article has referred to Lap Dog, Watch Dog, Guard Dog, and Attack Dog. There is another dog that we believe has a place in the pack, and that is a Support Dog. In a linear sense it would typically sit between Lap Dog and Watch Dog or occasionally sit between Watch Dog and Guard Dog.
There are justifiable concerns that can come with the concept of a Support Dog. A common concern is that ‘advice and guidance’ can quickly become a slippery slope for an issue like regulatory capture. This is because by giving (specific) advice on what compliance could look like means the regulator assumes responsibility for the regulated entity’s obligation.
However, that is not to say that a corresponding regulatory posture that involves some element of a Support Dog should not be used in appropriate contexts. The (general) need for regulators to educate and support regulated entities to help them understand their obligations is not in question. But rather that from time to time it may be necessary for regulator’s to provide regulated entities with more (specific) ‘support to comply’ materials or information. Such as when:
• regulators are establishing a new regulatory regime/scheme, i.e. with a defined honeymoon period, or a staged introduction of requirements or offences;
• the regulatory regime/scheme is offering an amnesty, i.e. think firearms amnesty; or
• the regulated industry or sector has gone through some major disruption or regulatory failure which is beyond their control, i.e. think Covid-19 or the Global Financial Crisis respectively.
Regulatory posture, no matter how framed, is a real issue for regulatory practitioners, regulatory managers, regulatory executives and regulatory boards.
We believe a defined, documented, and demonstrable regulatory posture has significant benefits for regulators, including that it can assist with:
• regulatory practice;
• regulatory delivery;
• regulatory outcomes; and
• advancing the regulatory profession itself.
We leave you with three key points to reflect upon, using different regulatory postures and different dogs as a point of comparison:
• agencies often gravitate to one type of dog, because they are familiar with that dog;
• agencies are complex, they can’t just have and rely on one type of dog; and
• agencies should be thinking of the benefits of using different dogs, rather than a specific type of dog.
Finally, whatever your choice, make it purposefully – and don’t let the tail wag the dog! •
[i] See Pink, G. (2021). Navigating Regulatory Language: An A to Z Guide. Canberra: RECAP Consultants Pty Ltd. (p. 231).
[ii] See Pink, G. 2021 (pp. 231-232).
[iii] Use of the word attack here is not meant to imply aggression. It is a reference to having the tenacity and ability to ‘fight’ as part of prosecution or litigation that can occur in confrontational and adversarial contexts.
[iv] The three main regulatory domains are economic, environmental, and social. It is not uncommon for a regulator to be anchored in and/or identify strongly with one domain, with their regulatory work intersecting with two or all three domains. For additional information see Pink 2021, p. 216.
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