AI-Assisted Export Permit Processing for Canadian Exporters
Enforcement
What it collects that can identify you
- Applicants (importers and exporters) submit personal and business information as part of their permit application through Secure Channel, including identity details required to process the application.
- Applicants submit export applications and certificates containing trade activity data, including details about the goods to be exported, their destination, and uploaded supporting data files.
Also collects operational data, which is anonymized data.
- Run by
- Global Affairs Canada (GAC)
- Where
- No fixed location
- Kept
- Not stated by the Helpful Places.
- Shared with
- Accountable organization, Me
What it is for
EXCOL is an online system operated by Global Affairs Canada that allows exporters and importers to submit permit applications electronically. The system automatically grants certain types of permits when specific rules-based conditions — such as available import quotas — are met, without human review. Users should know that AI and automated decision-making are in use, but this is not currently disclosed to them at the point of interaction.
What it collects and what happens to it
Data taken in
- Applicants (importers and exporters) submit personal and business information as part of their permit application through Secure Channel, including identity details required to process the application.
- Applicants submit export applications and certificates containing trade activity data, including details about the goods to be exported, their destination, and uploaded supporting data files.
- The system consults quota availability data for importers and exporters as part of the rules-based automatic permit grant process. This operational data determines whether automatic issuance conditions are met.
Processing
- Rules-based processing logic (within NEICS and NEXCOL) evaluates applications against defined permit conditions such as quota availability and eligibility criteria to automatically grant or route permits without human intervention.
What it does
- The NEICS and NEXCOL systems apply rules-based logic to automatically determine whether an export permit application meets the conditions for automatic grant — for example, whether sufficient import quota is available. No human reviewer is involved in automatically granted permit decisions.
Outputs
- The system produces automatic permit grants or denials for export permit applications when specific rules-based conditions are satisfied. These are binding regulatory determinations that directly affect the applicant's ability to export controlled goods.
Run by
- Global Affairs Canada is the federal department responsible for deploying and operating the Export Control On-Line System (EXCOL), which processes export and import permit applications on behalf of the Government of Canada.
Built by
- CGI Group Inc. is the vendor responsible for developing the EXCOL system on behalf of Global Affairs Canada.
Kept for
Not stated by the Helpful Places.
Shared with
- Application data and permit records submitted through EXCOL are accessible to Global Affairs Canada for the administration of export and import controls.
- Applicants can access their own submitted export applications and certificates through the EXCOL online portal using Secure Channel authentication.
Stored
Not stated by the Helpful Places.
How to read the colours
Can it identify you?
- Anonymized data
- Data about people with the link to who is broken. Stripped of identifiers, blurred, aggregated, or noised so this system can’t reasonably tie a record back to an individual.
- Pseudonymous data
- Each person’s data is tied to a token (hash, ID, template) that lets this system recognise the same person across events, but the token itself doesn’t reveal a name. Reidentification is possible with extra information.
- Identifiable data
- The data either contains a direct identifier (name, address, account name, recognisable face or voice, plate number) or carries a token this system uses to look up legal identity during processing.
Who completes the loop?
- Human decides
- This mode suggests; a person decides what to do next. The AI is always advisory — a human is in the loop on every decision. Example: a triage tool ranks cases for a clinician who chooses which to see first.
- Human executes
- This mode decides; a person carries out the result. Example: an optimizer plans the day’s trash-collection routes, and drivers run them.
- Autonomous
- This mode decides and acts on its own. No person reviews each decision or carries out the resulting action.
Definitions from the DTPR standard. Amber is about your data, violet about who decides. The fuller the shape and the deeper the colour, the more identifying the data or the less a person is involved.
- AI registerGovernment of Canada Algorithmic Impact Assessment Registry — EXCOL (2526-GAC-AMC-005)Global Affairs Canada AI Register entry 2526-GAC-AMC-005, accessed 2026-05-08.
- AI registerGovernment of Canada AI Register — EXCOL (2526-GAC-AMC-005)
- AI registerGovernment of Canada AI Register — EXCOL (2526-GAC-AMC-005)
- Register entryPublished by the Helpful Places. Reference 245d1d89. This disclosure was drafted with AI assistance.Schema: ai@2026-05-06-beta
What you can do
Ask about this system
Questions go to the Helpful Places, not the vendor.
Your rights
- Right to Be Informed of AI UseUsers of EXCOL currently have a right to be informed when AI or automated decision-making is in use, but the register entry confirms that AI use is not disclosed to users. Affected persons may contact Global Affairs Canada to request information about how their permit application was processed.
- Right to ContestApplicants whose permit applications are automatically denied or processed may have avenues to challenge such decisions through Global Affairs Canada's administrative processes. The register does not describe a specific contestation mechanism for automated decisions within EXCOL.
Risks and safeguards
- Civil liberties harmThe system makes automatic regulatory decisions affecting individuals' and businesses' rights to export goods without disclosing to users that AI and automated decision-making are in use. The lack of disclosure limits users' ability to understand or contest decisions. No mitigation for the non-disclosure is described in the source material; this represents a significant transparency gap under Canadian algorithmic accountability principles.