# Bureaucratic Silences: What the Canadian AI Register Reveals, Omits, and Obscures

arXiv: https://arxiv.org/abs/2604.15514 · HTML: https://mlsanity.com/paper/2604.15514/

## Key facts

- No citing papers in the map yet (data through 14 Oct 2026).
- Builds on 33 of its 132 references that are in the map.
- First posted on arXiv 16 Apr 2026.

## Builds on (most cited first, 30 of 33)

- [Datasheets for Datasets](https://mlsanity.com/paper/1803.09010/) (2018)
- [Model Cards for Model Reporting](https://mlsanity.com/paper/1810.03993/) (2018)
- [Closing the AI Accountability Gap: Defining an End-to-End Framework for Internal Algorithmic Auditing](https://mlsanity.com/paper/2001.00973/) (2020)
- [Examining Gender and Race Bias in Two Hundred Sentiment Analysis Systems](https://mlsanity.com/paper/1805.04508/) (2018)
- [The Ethics of AI Ethics -- An Evaluation of Guidelines](https://mlsanity.com/paper/1903.03425/) (2019)
- [Black-Box Access is Insufficient for Rigorous AI Audits](https://mlsanity.com/paper/2401.14446/) (2024)
- [Understanding and Evaluating Racial Biases in Image Captioning](https://mlsanity.com/paper/2106.08503/) (2021)
- [Explainability Fact Sheets: A Framework for Systematic Assessment of Explainable Approaches](https://mlsanity.com/paper/1912.05100/) (2019)
- [Fairness and Accountability Design Needs for Algorithmic Support in High-Stakes Public Sector Decision-Making](https://mlsanity.com/paper/1802.01029/) (2018)
- [Everyday algorithm auditing: Understanding the power of everyday users in surfacing harmful algorithmic behaviors](https://mlsanity.com/paper/2105.02980/) (2021)
- [Understanding accountability in algorithmic supply chains](https://mlsanity.com/paper/2304.14749/) (2023)
- [Understanding Practices, Challenges, and Opportunities for User-Engaged Algorithm Auditing in Industry Practice](https://mlsanity.com/paper/2210.03709/) (2022)
- [Worldwide AI Ethics: a review of 200 guidelines and recommendations for AI governance](https://mlsanity.com/paper/2206.11922/) (2022)
- [Biases in Generative Art -- A Causal Look from the Lens of Art History](https://mlsanity.com/paper/2010.13266/) (2020)
- [Outlining Traceability: A Principle for Operationalizing Accountability in Computing Systems](https://mlsanity.com/paper/2101.09385/) (2021)
- [The Principles of Data-Centric AI (DCAI)](https://mlsanity.com/paper/2211.14611/) (2022)
- [A Human-Centered Review of the Algorithms used within the U.S. Child Welfare System](https://mlsanity.com/paper/2003.03541/) (2020)
- [A Framework of High-Stakes Algorithmic Decision-Making for the Public Sector Developed through a Case Study of Child-Welfare](https://mlsanity.com/paper/2107.03487/) (2021)
- [Under the Morphosyntactic Lens: A Multifaceted Evaluation of Gender Bias in Speech Translation](https://mlsanity.com/paper/2203.09866/) (2022)
- [The "Colonial Impulse" of Natural Language Processing: An Audit of Bengali Sentiment Analysis Tools and Their Identity-based Biases](https://mlsanity.com/paper/2401.10535/) (2024)
- [Algorithmic Harms in Child Welfare: Uncertainties in Practice, Organization, and Street-level Decision-Making](https://mlsanity.com/paper/2308.05224/) (2023)
- [Rethinking "Risk" in Algorithmic Systems Through A Computational Narrative Analysis of Casenotes in Child-Welfare](https://mlsanity.com/paper/2302.08497/) (2023)
- [The DSA Transparency Database: Auditing Self-reported Moderation Actions by Social Media](https://mlsanity.com/paper/2312.10269/) (2023)
- [Lazy Data Practices Harm Fairness Research](https://mlsanity.com/paper/2404.17293/) (2024)
- [Improving governance outcomes through AI documentation: Bridging theory and practice](https://mlsanity.com/paper/2409.08960/) (2024)
- [Generating Full Length Wikipedia Biographies: The Impact of Gender Bias on the Retrieval-Based Generation of Women Biographies](https://mlsanity.com/paper/2204.05879/) (2022)
- [Automated Transparency: A Legal and Empirical Analysis of the Digital Services Act Transparency Database](https://mlsanity.com/paper/2404.02894/) (2024)
- ["This is not a data problem": Algorithms and Power in Public Higher Education in Canada](https://mlsanity.com/paper/2403.13969/) (2024)
- [The Datafication of Care in Public Homelessness Services](https://mlsanity.com/paper/2502.09043/) (2025)
- [The "Who", "What", and "How" of Responsible AI Governance: A Systematic Review and Meta-Analysis of (Actor, Stage)-Specific Tools](https://mlsanity.com/paper/2502.13294/) (2025)

## Abstract (arXiv)

In November 2025, the Government of Canada operationalized its commitment to transparency by releasing its first Federal AI Register. In this paper, we argue that such registers are not neutral mirrors of government activity, but active instruments of ontological design that configure the boundaries of accountability. We analyzed the Register's complete dataset of 409 systems using the Algorithmic Decision-Making Adapted for the Public Sector (ADMAPS) framework, combining quantitative mapping with deductive qualitative coding. Our findings reveal a sharp divergence between the rhetoric of "sovereign AI" and the reality of bureaucratic practice: while 86% of systems are deployed internally for efficiency, the Register systematically obscures the human discretion, training, and uncertainty management required to operate them. By privileging technical descriptions over sociotechnical context, the Register constructs an ontology of AI as "reliable tooling" rather than "contestable decision-making." We conclude that without a shift in design, such transparency artifacts risk automating accountability into a performative compliance exercise, offering visibility without contestability.
