This project conducted a data-sovereignty due-diligence review of 76 AI inference providers reachable through OpenRouter, evaluated against Canadian PIPEDA / provincial data-sovereignty requirements. US-based and allied-jurisdiction providers are acceptable for this engagement; the single red line is client data flowing to, or being processed within, mainland China (PRC residency, PRC-state or Chinese-corporate ownership, or proxying inference to a China-based upstream). One additional listed OpenRouter entry ("fake-provider") was excluded as a non-entity and is not part of the evaluated set.
Of the 76 providers assessed, 35 are a clean GO, 27 are a CONDITIONAL-GO (acceptable subject to named conditions — a signed DPA, enabling Zero Data Retention, region-pinning, or resolving an unlaunched OpenRouter integration), 8 are a CONDITIONAL-NO-GO, and 6 are an outright NO-GO. In plain terms: 62 of 76 providers clear the sovereignty bar in some form, but only 35 clear it cleanly with no material caveats. 14 of 76 fail the criteria and should not receive Canadian client data without a structural change on the provider's side.
The 14 failures cluster into four recurring patterns rather than being scattered idiosyncrasies: (1) proxy/aggregator architectures that route prompts to undisclosed or China-resident upstream models (AionLabs, AI Crucible, Infermatic, Switchpoint); (2) unverifiable or non-existent corporate entities that make accountability impossible to establish (Infermatic, "stealth"); (3) decentralized or permissionless marketplace architectures that cannot pin the physical location of inference and therefore cannot guarantee geography (AkashML, Ambient, io.net, Perceptron's default consumer license); and (4) one provider — SiliconFlow — where the underlying corporate structure itself is Chinese-founded and Beijing-headquartered with PRC state-linked investors, making it a direct instance of the red line rather than a proxy risk to it. A related fifth pattern shows up among conditional passes: several providers (nCompass, Inferact, Cirrascale, Crusoe, Avian, HeyGen, Tenstorrent) are architecturally sound but are not currently live OpenRouter integrations, so their conditional status reflects availability risk rather than a sovereignty defect.