With the passage of Bill 96, which dramatically expands French language use requirements in Quebec workplaces, your organization needs to review if language practises in Quebec to ensure compliance with the many new requirements, including the following:
- Employers with over 25 Quebec employees (rather than the previous 50) must prepare and submit a “francisation” plan to the Office de la Langue Francaise (the “OLF”) i.e. a plan describing how French is going to be used or introduced to comply with Bill 96 requirements;
- All template or standard form Employment Agreements (including those we have drafted for your organization) (“EA”) must be made available in French even if the parties prefer and are more fluent in English and ultimately agree to sign an EA in English;
- When setting a fluency in English job requirement, employers must show they have used all reasonable efforts to avoid such a requirement and accommodate unilingual francophones: this will be onerous paperwork for many roles in pan-Canadian and international businesses and apply even in Montreal with its high level of overall bilingualism and national and international business community; and
- The OLF will have a “snitch” line to facilitate citizen complaints about non-compliance and enhanced draconian investigation and search and seizure powers.
Our Quebec partner firm Loranger Marcoux will be assisting our clients and our firm with compliance. Here is a link to their more detailed explanation (in English!) of the implications of Bill 96:
Some of these new obligations will take effect on the date that the Bill is sanctioned by the Lieutenant Governor (which may occur this week), so this should be a priority.
If you want more information on this topic, you can contact us at:
Geoffrey Howard: firstname.lastname@example.org
Sebastian Chern: email@example.com