Which colleges and universities the regulation covers
The regulation reaches every institution that FIPPA calls an educational institution, a term the Act defines as a college of applied arts and technology or a university.12 Section 2 of O. Reg. 51/26 uses exactly that wording: “an educational institution as defined in subsection 2 (1) of the Freedom of Information and Protection of Privacy Act”. Those institutions carry the cyber security duties from 1 July 2026, and the provincial guidance lists colleges and universities among the sectors in scope.3
Where an organization sits at the edge of that wording, for example an affiliated or federated college, reading the definition is a question for the institution's counsel. Our work starts once the institution knows it is in scope, or chooses to run the same assessment voluntarily; the Ontario CMA Tool is open to organizations outside the regulation as well.5 The O. Reg. 51/26 overview covers hospitals, school boards and children's aid societies.
| Provision | What the institution must do | In force | Source |
|---|---|---|---|
| O. Reg. 51/26, ss. 3–4 | Run a cyber security program; designate a primary point of contact and an alternate, both in senior management | 1 July 2026 | 1 |
| O. Reg. 51/26, ss. 5–6 | Complete an initial maturity assessment within one year, then at least once every two years; send a summary to the ministry CISO within 30 business days | 1 July 2026; first assessment by 1 July 2027 | 1 |
| O. Reg. 51/26, s. 7 | Report a critical cyber security incident within 72 hours of confirming it | 1 July 2026 | 1 |
| FIPPA, s. 38 (3) | Prepare a written privacy impact assessment before collecting personal information | 1 July 2025 | 2 |
| FIPPA, s. 40 (5) and s. 40.1 | Keep reasonable safeguards; report breaches with a real risk of significant harm to the Commissioner, notify the people affected and keep a record of each | 1 July 2025 | 2 |
