Quebec Bill 96 and AI: French Language Obligations for Software and Technology Businesses

What Bill 96 is — and what it actually amends

Bill 96 is not a new law from scratch. It is a sweeping amendment to the Charter of the French Language (RLRQ, c. C-11), Quebec’s foundational language statute — the law commonly called “Bill 101” — which has governed the use of French in commerce, labour, and public life since 1977. Bill 96 received royal assent on June 1, 2022 and was deliberately phased in over three years to give businesses time to adapt.

The law’s formal name is “An Act respecting French, the official and common language of Québec.” Its purpose is stated explicitly: to reverse French-language decline in Quebec by re-asserting French as the normal and everyday language of work, commerce, and public services — including digital products and services.

Enforcement falls to the Office québécois de la langue française (OQLF), Quebec’s language regulator. The OQLF administers the francization program, issues compliance notices, receives complaints, and — as of June 2025 — holds expanded authority to conduct proactive inspections without waiting for a complaint to be filed.

The phased timeline: what came into force and when

Bill 96 was deliberately staged. Understanding which provisions are already in force (versus transitional) matters for compliance planning:

June 1, 2022 — royal assent and immediate provisions

On the date of royal assent, several provisions took immediate effect: new employee rights to work in French; the right of consumers to receive service in French from businesses operating in Quebec; and expanded rights to receive government services, documents, and contracts in French.

June 1, 2023 — contracts of adhesion and translation rights

Contracts of adhesion — standard-form contracts where one party sets the terms without negotiation — must be presented in French first, including those concluded online or by phone. Parties can subsequently agree to a contract in another language, but the French version must be presented first and must be provided before any English (or other language) version is offered. This catches software terms of service, online purchase agreements, SaaS subscription contracts, and click-wrap licences when at least one party is in Quebec.

June 1, 2025 — the expansion businesses felt most

The June 2025 wave was the most operationally significant for technology businesses. According to analysis by DLA Piper (June 2025) and BCF Business Law (June 2025), the provisions that came into force on June 1, 2025 include:

• Lowered francization threshold: businesses with 25–49 employees in Quebec must now register with the OQLF and undergo the francization process. Previously, only businesses with 50 or more employees were subject to this requirement. Businesses with 100 or more employees must additionally establish a joint francization committee.
• Markedly predominant French signage: any message displayed in a publicly accessible place — signs, shop windows, vehicles, or any display visible from outside — must ensure that French is “markedly predominant,” meaning French text must be at least twice as large and equally or more visible than text in any other language.
• Product inscriptions (labels): all product labels must be in French, with no other language more prominent. Trademarks may still appear in another language if no French version is federally registered, but this is a narrow exception.
• Strengthened OQLF enforcement powers: the OQLF gained authority to inspect businesses proactively — without a prior complaint — and can now review websites, digital interfaces, contracts, and internal documentation as part of those inspections.

Source: DLA Piper, “Quebec’s language laws changed this week: Here’s what you need to know,” June 2025 (dlapiper.com); BCF Business Law, “The Charter of the French Language: New Obligations as of June 2025,” June 2025 (bcf.ca). Verify current program status with the OQLF at oqlf.gouv.qc.ca before taking compliance action.

What Bill 96 requires from software and technology products

The Charter’s software and technology provisions are not new — they existed in Bill 101 — but Bill 96 extended their reach and sharpened their requirements. The rules apply along two axes: software used by employees, and software or interfaces directed at consumers.

Employee-facing software and internal tools

Under the Charter as amended, employees in Quebec have the right to work in French. This right flows through to software: employers may not require employees to use software — including internal tools, ERPs, CRMs, project management systems, or AI assistants — exclusively in a language other than French when a French version is available.

The operative test is whether a French version exists. If the software vendor offers a French language option, the employer must make it available to Quebec employees as an option at minimum. This applies to commercially available software, internal tools, and software deployed via SaaS. It also applies to AI-powered tools used by employees — productivity assistants, code-completion tools, document-summarization tools, and internal chatbots — if those tools are capable of operating in French.

Practically, this means:

• AI coding assistants (GitHub Copilot, Cursor, similar) used by Quebec-based employees should have French language settings enabled if the tool supports them
• Internal AI chatbots or document-retrieval tools (RAG systems, help-desk bots) deployed to Quebec employees need to be capable of responding in French
• Internal documentation, training materials, and onboarding documents for Quebec employees must be provided in French
• Employment contracts, offer letters, performance reviews, and disciplinary notices for Quebec employees must be in French (English copies may also be provided, but French comes first)

Customer-facing interfaces: websites, portals, and chatbots

Businesses serving Quebec consumers must offer their services in French. For digital products and e-commerce sites, this means:

• A fully functional French version of the website, with the same content, features, and functionality as any English version — not a reduced-feature or machine-translated afterthought
• Customer service channels available in French: live chat, email support, ticketing systems, and phone
• AI-powered customer service tools (chatbots, virtual assistants, automated response systems) must be capable of serving customers in French, with equivalent functionality to any English-language version
• Product descriptions, terms of service, privacy policies, and checkout flows in French
• Error messages, system notifications, and app interfaces in French when a French version exists

The principle, as expressed in the Charter, is that French must be available on terms no less favourable than another language, with equivalent technical capabilities. Offering a degraded French-language experience — slower response times, fewer features, or a bot that escalates to English faster than it escalates to a human French-speaking agent — is not compliant.

AI chatbots and automated customer service: the evolving interpretation

The Charter’s consumer-service provisions logically extend to AI-powered customer tools: an AI chatbot serving Quebec customers is a form of customer service, and customer service must be available in French. The OQLF’s June 2025 enforcement expansion includes reviewing digital channels — which would include AI-driven interfaces — as part of proactive inspections.

Important hedge: the OQLF had not published specific formal guidance on large language models, generative AI tools, or RAG-based knowledge systems as a distinct category at the time of writing (June 2026). The general software and customer-service provisions of the Charter are the applicable framework, but how the OQLF will interpret specific edge cases — for example, whether a model that can respond in French satisfies the obligation even if it defaults to English unless prompted — is a legal interpretation question. Businesses deploying AI customer tools into Quebec should obtain specific legal advice on this point and document their compliance approach. See D-Central’s AI consulting for Quebec businesses for an orientation on the landscape.

The francization program: what businesses with 25+ Quebec employees must do

The francization program is the Charter’s mechanism for ensuring that French becomes the normal language of work inside Quebec businesses. As of June 1, 2025, the program covers businesses with 25 or more employees in Quebec — down from 50. According to BCF Business Law (June 2025), the process unfolds in stages:

1. Registration with the OQLF — within six months of reaching the 25-employee threshold in Quebec, the business must register formally with the OQLF
2. Linguistic situation analysis — three months after confirmed registration, the business must complete an analysis of French-language use within the organization, covering communications, software tools, training materials, documentation, and management practices
3. Francization program (if required) — if the analysis reveals that French is not the normal language of work, the OQLF may require the business to implement a francization program with specific objectives and timelines
4. Francization committee (100+ employees) — businesses with 100 or more Quebec employees must establish a joint francization committee composed of representatives from management and employees, responsible for overseeing the linguistic analysis and monitoring progress

For technology companies — particularly SaaS businesses, AI firms, and software product companies whose Quebec-based teams work in English because of market, international clients, or technical tooling — BCF Business Law notes that “rigorously reconciling the obligation to francize with operational imperatives calls for a strategic and pragmatic approach.” The obligation is real; the implementation requires case-by-case analysis of what is operationally feasible and what the OQLF will accept.

This is orientation on the published program structure, not legal or compliance advice. The OQLF’s practice in applying these obligations to technology businesses is still developing. Consult a Quebec employment or language-law lawyer before initiating your francization process.

OQLF enforcement: what the regulator can now do

Bill 96 materially expanded the OQLF’s enforcement toolkit. Prior to the 2022 amendments, OQLF enforcement was primarily complaint-driven. Under the amended Charter, the OQLF can:

• Conduct proactive inspections — visit businesses, request documentation, and review digital interfaces without a prior complaint having been filed
• Issue compliance notices — formal notices requiring specific corrective action within a defined time frame
• Assess fines — penalties range from $3,000 to $30,000 per offence for corporations, with subsequent violations subject to doubled or tripled penalties (according to francoflex.com and other published sources; verify current penalty schedules at the OQLF)
• Direct liability to directors — penalties can be assessed against corporate directors individually in addition to the corporation
• Seek court orders — in serious cases, the OQLF can apply to the courts for injunctive relief, requiring immediate compliance
• Revoke francization certificates — for businesses that have received a certificate but subsequently fall out of compliance

The OQLF’s proactive inspection mandate now explicitly includes digital channels: websites, online contracts, customer-facing interfaces, and internal document systems are within scope. For businesses operating AI-powered tools visible to Quebec consumers or employees, this is material.

Why local AI infrastructure has a compliance advantage

One structural benefit of on-premises, locally hosted AI infrastructure — as opposed to shared cloud AI services — is that it gives businesses full control over the language of the interface, the default response language, the training data, and the system prompt governing model behaviour. A cloud AI provider’s French-language support is defined by the provider’s product decisions; a locally deployed open-weight model can be configured, fine-tuned, and constrained to operate exclusively in French.

This matters for Bill 96 compliance in several ways:

• Customer-facing AI in French: a self-hosted model can be configured with a French-only system prompt and evaluated entirely against French-language test cases — you control the language contract, not the vendor
• Employee AI tools with French defaults: internal AI assistants (code review, document summarization, internal search) can be deployed with French as the default interface and response language, satisfying the employee-tools obligation without depending on a vendor to ship a French language pack
• Data residency alignment: Law 25 (Quebec’s private-sector privacy law) requires that personal information leaving Quebec be subject to a privacy impact assessment — local AI keeps that data in-province, eliminating a separate regulatory exposure on top of Bill 96. See Quebec data residency obligations and the Law 25 privacy impact assessment guide for detail.
• Audit trail: local inference logs are yours — you can produce them for an OQLF inspection without depending on a cloud provider’s data-export process

For a practical overview of locally hosted AI options available in Canada, see local LLM in Canada and the sovereign stack guide. For air-gapped deployments where data never leaves the building, see air-gapped AI coding for Canadian businesses. For private document retrieval that does not require sending documents to a cloud service, see RAG for Canadian businesses (Law 25-compliant).

Bill 96 and Bill 96’s relationship to other Quebec and federal frameworks

Bill 96 does not exist in isolation. Businesses operating AI and software products in Quebec should be aware of how it interacts with adjacent regulatory frameworks:

Law 25 (Act respecting the protection of personal information in the private sector)

Law 25 is Quebec’s private-sector privacy law, substantially amended in three phases (2022–2023). It requires: Privacy Impact Assessments (PIAs) for personal information transferred outside Quebec; appointment of a privacy officer; enhanced consent for sensitive data; and data minimization obligations. An AI tool that processes personal information about Quebec residents — employees, customers, patients — is subject to Law 25 in addition to Bill 96. See Quebec data residency for a summary of the data-movement obligations.

Bill 64 / Law 25 and AI decision-making

Law 25 includes provisions on automated decision-making: when a decision based solely on automated processing of personal information produces legal or significant effects on an individual, the person has the right to be informed that a decision is made exclusively by automated means and to have a human review it. This is distinct from Bill 96 but may be relevant to AI tools making hiring decisions, credit decisions, or service-eligibility determinations for Quebec residents.

Federal privacy (PIPEDA / Bill C-27)

Quebec businesses that engage in cross-provincial or international transactions are also subject to federal privacy law (currently PIPEDA). The proposed federal Bill C-27 (Consumer Privacy Protection Act) would update the federal framework, but as of June 2026 it had not yet received royal assent — its status should be verified before relying on it for compliance planning. Quebec’s Law 25 applies regardless of the federal framework’s status.

Bill 109 (proposed — not yet enacted)

In May 2025, the Quebec government tabled Bill 109, proposing an Act respecting the discoverability of French-language cultural content in the digital environment. According to DLA Piper (2025), Bill 109 would target digital platforms and device manufacturers, mandating French-language interfaces by default and prioritisation of French content. As of June 2026, this bill had not yet received royal assent — it should be monitored but not relied upon as current law. Verify current legislative status at assnat.qc.ca before acting.

Quick compliance orientation for technology businesses

This is an orientation framework, not legal advice. The appropriate starting point for any compliance program is a review with a Quebec language-law lawyer and, where required, formal engagement with the OQLF.

Area	Obligation (as of June 2025)	Who is covered
OQLF registration	Register within 6 months of reaching 25 Quebec employees; complete linguistic situation analysis within 3 months of registration	Businesses with 25+ employees in Quebec
Employee software / internal AI tools	Must be available in French when a French version exists; employees cannot be required to use non-French tools exclusively	All employers with Quebec employees
Customer-facing website	Fully functional French version with equivalent content and features; not a secondary or reduced-functionality track	All businesses selling to Quebec consumers
Customer AI / chatbots	Must be able to serve customers in French with equivalent capability to any English version; French default is safest interpretation	All businesses with AI customer tools serving Quebec
Contracts of adhesion	Must be presented in French first; English version may follow if consumer requests it	Any business using standard-form contracts with Quebec parties
Product labelling	Must be in French; no other language more prominent; trademarks may appear in English if no French version is federally registered	Businesses selling physical or digital products in Quebec
Public signage	French markedly predominant (at least 2× the size / visual prominence of other languages)	Businesses with publicly visible signage in Quebec
Employment documents	Offer letters, contracts, evaluations, disciplinary notices must be in French for Quebec employees	All employers with Quebec employees

For strategic orientation on operating AI systems in Quebec within a sovereignty-respecting architecture, see Canadian digital sovereignty and D-Central’s Quebec AI consulting orientation.

Frequently asked questions

Does Bill 96 apply to businesses outside Quebec?

Partially. Businesses based outside Quebec but selling products or services to Quebec consumers, or employing workers in Quebec, are subject to the provisions relating to commerce and consumer service — including requirements that websites be available in French and that customer-facing AI tools can operate in French. The francization program (employee-threshold registration) applies to businesses with 25 or more employees in Quebec, so a company with a single Quebec-based remote employee does not immediately trigger francization obligations. The threshold is based on the number of employees whose work is performed in Quebec, not total company headcount. Consult a lawyer to confirm your specific coverage.

Does a fully bilingual website satisfy Bill 96?

A bilingual website is not automatically sufficient if it presents English and French as co-equal options without French being the default or the first option offered. The Charter requires that French be available on terms no less favourable than another language. For contracts of adhesion (including online terms of service and purchase agreements), French must be offered first. The safest architectural approach is a French-default site with an option to switch to English, not an English-default site with a language toggle. Consult a language-law lawyer for your specific situation.

Is my SaaS product covered if it has Quebec customers?

If your SaaS product is a service consumed by Quebec businesses or consumers, the consumer-service and commerce provisions apply. Your product interface, help documentation, support communications, and contracts with Quebec parties should be available in French. The degree of obligation depends on the nature of the product, how it is sold, and how it is used — this is a legal analysis question, not a bright-line rule. Obtain specific advice before assuming you are outside scope.

What does “when a French version exists” mean for AI software?

For commercially available software, the test is whether the vendor offers a French language option — if so, the employer must make it available to Quebec employees. For custom-built or self-hosted AI tools, the question shifts to whether you have built (or can build) a French-language capability. The OQLF’s specific guidance on this interpretation for AI systems had not been published at the time of writing. Businesses building or deploying AI tools for Quebec employees should document their French-language capability assessment and seek formal legal advice on their obligations.

What are the penalties for non-compliance?

According to publicly available sources (francoflex.com, language-law analysis firms), fines under the amended Charter run from $3,000 to $30,000 per offence for corporations, with subsequent violations subject to doubled or tripled penalties. Directors can be held personally liable. The OQLF can also seek court orders and revoke francization certificates. These figures are from published third-party analyses — verify current penalty schedules with the OQLF directly or through legal counsel.

Does Bill 96 cover AI-generated content or AI training data?

The Charter as amended does not contain specific provisions addressing AI training data or AI-generated content as distinct categories. The general consumer-service and software obligations are the applicable framework: if an AI system generates customer-facing content in Quebec, that content must be available in French with equivalent quality. Whether the OQLF will develop specific guidance on French-language requirements for model outputs, training data composition, or model fine-tuning is not settled as of June 2026. This is an area where the regulatory interpretation is still developing and legal counsel should be consulted.

How does Bill 96 interact with Law 25 for AI systems?

They are separate obligations that can overlap for AI systems. Law 25 governs personal information — collection, use, transfer, and automated decision-making. Bill 96 governs language — the language of the interface, the contract, the tool, and the communication. An AI system that processes personal information about Quebec residents and serves those residents through a customer interface must comply with both: Law 25 for data handling and Bill 96 for language. See Quebec data residency obligations and the Law 25 PIA guide for the data-side framework.

Can I use machine translation to meet Bill 96 requirements?

Machine translation of low-stakes internal documentation may be acceptable in some circumstances, but customer-facing content, legal contracts, and AI customer-service interfaces are higher-stakes contexts where machine translation quality matters significantly. A poorly translated contract may not effectively communicate the French-version obligation. The Charter requires French on terms no less favourable — a visibly machine-translated interface may not satisfy that standard in the OQLF’s view. Human review of machine-translated customer-facing content is the conservative approach.

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Legal and regulatory notice: The information on this page is sourced from the Charter of the French Language (RLRQ, c. C-11) as amended by Bill 96 (2022), the Office québécois de la langue française (oqlf.gouv.qc.ca), and third-party legal analyses published by DLA Piper (June 2025, dlapiper.com) and BCF Business Law (June 2025, bcf.ca). This page is an orientation resource — it is not legal advice, is not a substitute for legal advice, and does not create a lawyer-client relationship. Quebec language law obligations are fact-specific and evolve as the OQLF issues guidance and the courts interpret the Charter. Consult a lawyer experienced in Quebec language law before making compliance decisions for your organization. Regulatory interpretation of AI-specific obligations under the Charter is still developing as of June 2026.