Companies with 25 to 49 employees: registered with the Office québécoise de la langue française?

As of June 1, 2025, companies employing 25 or more individuals in Quebec for a period of six months will be required to register with the Office québécois de la langue française (OQLF) in order to initiate a francization process.

Legislative context

On June 1, 2022, the Act respecting French, the official and common language of Québec (Bill 96) received assent. Subsection 83(1) of this Act amends section 139 of the Charter of the French Language by lowering to 25 the number of employees a company must have to be required to register with the OQLF. This provision will come into force on June 1, 2025.

What is the francization process for companies with 25 or more employees?

First step: The company must register with the OQLF by submitting the appropriate form. Once the form has been received and reviewed, the OQLF will issue a registration certificate¹ to the company.

Second step: Within three months of the date of issue of the registration certificate, the company must conduct an analysis of its linguistic situation and submit it to the OQLF ². This analysis must also be completed by using a specific form.

Third step: If the OQLF assesses that the use of French is widespread at all levels of the company, it will issue a certificate of francization, without requiring the company to implement a francization program³.

However, if the OQLF assesses that the use of French is not generalized at all levels of the company, it notifies the company that it must adopt a francization program and submit it within three months of the date of receipt of such notice⁴.

After approving the francization program, the OQLF issues an attestation of implementation of the francization program⁵, requiring the company to comply with the elements and steps set out in its program, and to submit implementation reports to the OQLF every twelve months⁶. These reports, as well as the francization program itself, must be communicated to the company’s employees⁷.

When the company has completed the implementation of its francization program and the OQLF assesses that the use of French is widespread at all levels of the company, it issues a francization certificate⁸.

Fourth step: Every three years, a company holding a francization certificate must submit a report to the OQLF on the evolution of the French usage within the company⁹.

What are the consequences if a company fails to comply with its francization obligations?

When the OQLF identifies a breach of the provisions of the Charter of the French Language or one of its regulations, it can order the offender to comply¹⁰.

Failure to comply with such an order constitutes an offence, for which an individual may be subject to a fine from $700 to $7,000, and, in other cases, a fine ranging from $3,000 to $30,000¹¹.

Francization: a requirement for obtaining a grant or public contract

Section 152.1 of the Charter of the French Language provides, subject to certain exceptions, that the Administration¹² cannot enter into a contract with, or grant a subsidy to, a company when that company:

• does not hold a registration certificate;
• has not submitted, within the prescribed time, an analysis of its linguistic situation;
• does not hold a certificate of program implementation or francization certificate; or
• appears on the list of companies for which the OQLF has refused to issue a certificate, or for which it has suspended or revoked a certificate or attestation.

This provision, already applicable to companies with 50 or more employees, will be extended to companies with 25 to 49 employees as of June 1, 2025.

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^{Disclaimer: the content of this article provides only an overview of the subject and should not, under any circumstances, be construed as legal advice. Readers should not rely solely on this document to make decisions, but should seek legal advice tailored to their specific situation.}

• ^{1. Charter of the French Language.}
• ^{2.Id., s. 139, para. 3.}
• ^{3.Id., s. 140, para. 1.}
• ^{4.Id., s.. 140, para. 2 and 3.}
• ^{5.Id., s. 143, para. 1.}
• ^{6.Id., s. 143, para. 2 and 3.}
• ^{7.Id., s. 143, para. 4.}
• ^{8.Id., s. 145.}
• ^{9.Id., s. 146.}
• ^{10.Id., s. 177.}
• ^{11.Id., s. 205.}
• ^{12.Id., Appendix I.}

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