A leading concern about election integrity in 2025 isn’t systems hacking or the polls being flooded with ineligible voters. It’s digital misinformation and disinformation – the proliferation of low-quality and malicious information in the political space that has the potential to influence the outcome of any election.

Justice Marie-Josée Hogue observed this threat in the final report of the Public Inquiry Into Foreign Interference in Federal Electoral Processes and Democratic Institutions, which she chaired.

“In my view it is no exaggeration to say that at this juncture, information manipulation (whether foreign or not) poses the single biggest risk to our democracy,” she wrote. “It is an existential threat.”

She encouraged policymakers to take seriously the risks to Canadian democracy.

The growing risk across all levels of government

Misinformation and disinformation – whether generated domestically or on foreign soil – are not just problems for Canadian federal elections.

Examples in other countries include “voting machine glitch” rumours in the U.S. and what one Facebook executive called the “global disinformation epidemic” during the 2019 Philippine midterm elections.

Provincial and municipal elections in Canada are also vulnerable – perhaps municipal elections more so, given the historically observed lack of information around local candidates and issues, the limited resources of municipalities in election administration, their lack of legislative authority and enforcement powers, as well as a high degree of voter apathy.

Misinformation, though troubling, has always been a part of elections. Legislating our way out of it is not only challenging, but constitutionally risky as well because it can tread on the public’s right to free expression.

Disinformation – the intentional spread of knowingly false information – is different and requires enforceable consequences through modernized legislative frameworks and other steps to uphold electoral integrity at the municipal level.

Legislative gaps in Ontario’s Municipal Elections Act

For example, by modernizing Ontario’s municipal election laws, the province can establish clearer authority and enforcement mechanisms as well as accountability structures to deter and penalize those who intentionally seek to mislead voters.

The Ontario Municipal Elections Actcurrently lacks a framework to regulate digital disinformation. Penalties exist only for candidates and third-party advertisers who, under sections 88.3-88.5, must include mandatory information in campaign ads. Misleading or anonymous advertising may be subject to penalties up to $25,000.

Although, legislative gaps remain in putting the rules into practice and enforcing them, clearer guidelines and stronger enforcement could go a long way toward fixing these issues.

Change is possible and may soon be on the provincial horizon. In his recent post-election report, Greg Essensa, Ontario’s chief electoral officer, proposed legislative reforms that would enhance transparency for digital political advertising, expand his authority to order online content removal, and expand both enforcement powers and penalties for digital election violations.

Lessons from other provinces

Manitoba is one province setting the standard with legislative reforms in this area with fines of up to $20,000 a day for election disinformation, including so-called “deepfake” videos that use artificial intelligence and advanced editing techniques to create realistic but false images or videos of candidates.

Its recent legislation also includes penalties for intentionally misleading information about voter eligibility, the conduct of elections officials and the people or companies that provide ballots and vote-counting machines.

Elsewhere, Elections BC has the authority to investigate complaints related to campaign advertising, issue penalties for violations and order removal of unauthorized or restricted advertising. Such a model, combined with legislative reform, leaves its municipalities well-positioned to prevent disinformation.

But not all gaps are legislative. In Ontario, some challenges exist because of a lack of policy co-ordination between the province and its municipalities. With no centralized oversight and with no enforcement mechanisms at the municipal level, municipal clerks have limited authority and resources to respond to digital information threats.

 Absent a province-wide strategy of mandatory digital literacy or misinformation training for candidates and election officials, local officials are left to devise ad hoc strategies to counter misinformation and disinformation in real time rather than taking a systemic approach to recognizing, cataloguing and addressing digital threats.

What a “whole-of-society” approach could look like

So, how can municipalities work with Elections Ontario to support its recommendation to take a “whole-of-society approach” to disinformation in elections?

To some extent, disinformation can be addressed through revisions to the Municipal Elections Act that include provisions for digital campaign transparency, AI-generated content labeling and incorporating real-time misinformation response protocols that are particularly relevant for larger municipalities.

As we pointed out last year, Ontario’s 444 municipalities differ in size, resources and location. Therefore, any legislative or policy changes must be done with an eye to flexibility and applicability.

Aligning with the Elections Ontario recommendation, legislative reform around disinformation should empower election administrators to not only identify but also correct or remove false information.

Reconciliation in the age of AI and social media

Countering the threat of AI manipulation by authoritarian states

Second, the success of legislative reform requires centralized oversight. The legislature should empower Elections Ontario, integrity commissioners or a separate provincial body to monitor and intervene in cases of election-related misinformation. They would need the authority to issue take-down orders or to assign monetary penalties.

Establishing this central oversight alongside local election integrity partnerships to monitor misinformation trends and insights would help create more co-ordinated action.

This response may include public awareness campaigns, media monitoring, multilingual outreach and the sharing of best practices across municipalities.

Building public resilience

While public education and resilience-building are essential, they alone are not sufficient. Province-wide digital literacy campaigns ahead of elections, as well as training and toolkits for municipal election administrators, candidates and voters would at least standardize the availability of resources to Ontario election participants and voters.

Several jurisdictions, ranging from Elections Canada to its provincial counterparts, have used a proactive push strategy over YouTube and other social media to educate voters and debunk misinformation about voting times, tools and approaches.

Elections Ontario has formed a team to co-ordinate detection, response and preparedness against AI-driven misinformation and disinformation. While the scope of the team’s work is being finalized, it is anticipated that its activity will only increase as content-generation tools become more accessible.

None of these strategies are a silver bullet, but they could be meaningful ways to combat the problems.

Municipal elections may not be considered the epicentre of the fight against digital threats to elections but policymakers should consider what can be done to protect their unique vulnerability through a modernized legislative framework and the closure of policy gaps. A resilient and trustworthy democratic process requires no less.