Bill 96 for Employers: What Quebec's French Language Law Means for Your HR Practices

If you have employees in Quebec, Bill 96 changed your HR documentation obligations in 2022 — and the enforcement framework continues to expand. The Charter of the French Language was already strict; Bill 96 made it stricter.

This is the post for employers who hire in Quebec (or are about to) and need a working understanding of what they actually have to put in French, where the exceptions are, and where the penalties bite.

Background: the Charter and Bill 96

Quebec's Charter of the French Language (often called Bill 101) has been in force since 1977. It establishes French as the official language of the workplace and the language of normal and everyday work in Quebec. The Office québécois de la langue française (OQLF) is the regulator. The OQLF inspects, investigates complaints, and refers serious violations to prosecutors.

In 2022, the Quebec National Assembly passed Bill 96 (An Act respecting French, the official and common language of Québec). Bill 96 amended the Charter and several other Quebec statutes. The amendments tightened French-language obligations in business and HR, expanded the OQLF's enforcement powers, and increased penalties.

If your last operational read of Quebec's language regime was before 2022, the rules you remember are no longer the rules in force.

Employment documents that must be in French

Bill 96 was specific about employment documentation. The following must be drawn up in French, and where a parallel English (or other-language) version exists, the French version generally governs:

• Offer letters and individual employment contracts. The default is French. An employee can request to receive their individual contract in another language, but only if the parties expressly agree — and the French version remains the reference. You cannot require the employee to accept English-only documentation as a condition of hire.
• Job postings. Job postings must be in French. If posted in another language as well, the French version must be displayed in a manner at least as prominent as the other language.
• Application forms, performance reviews, and disciplinary documents. Documents that affect the individual employee's rights, working conditions, or status must be available in French.
• Internal communications of general application. Policies, manuals, training materials, and communications addressed to employees as a group must be in French. You can issue translations, but the French version is the operative one.

When English-only is permitted

The Charter contains narrow exceptions. The two practical ones for HR:

• International communications. Communications between Quebec operations and a parent company or affiliate outside Quebec, or with international clients/partners, can be in English. This is narrowly construed.
• Specific technical documents. Some specialized technical documentation can be in another language where the technical vocabulary is genuinely English-dominant. Again, narrow.

We recommend a conservative interpretation. If you are uncertain whether a document falls inside an exception, draft it in French and provide an English translation rather than the reverse. The reverse exposes you; the French-first approach does not.

Hiring requirements: when can you require French?

Bill 96 tightened the rules around requiring French (or any language other than French) as a condition of employment.

You cannot require knowledge of a language other than French unless the role genuinely requires it. Before posting a position with an English requirement, the employer must:

• Assess the actual language needs of the role
• Take reasonable steps to avoid imposing a language requirement (for example, by reorganizing duties so a single bilingual role isn't necessary)
• Document the rationale

Posting a job that says "fluent English required" without a documented justification is itself a Charter violation that can be enforced through OQLF complaint or civil claim by an applicant.

The mirror rule: requiring French is permitted (French is the language of work in Quebec), but you also can't impose a French requirement that gatekeeps a role for which French is genuinely not necessary. The Charter's language-of-work obligations are about ensuring French is usable, not about excluding non-Quebec-resident applicants.

Practical compliance for SMBs

If you have a small Quebec footprint and your HR templates are all in English, the practical work is:

• Translate your standard offer letter into French. Have it reviewed by a francophone legal professional, not run through machine translation.
• Translate your employee handbook, code of conduct, and policy library. Maintain both versions in parallel; whenever you update one, update the other.
• Localize your performance review templates. Even if your manager is anglophone, the performance review form delivered to a Quebec employee should be available in French.
• Build the bilingual habit into onboarding. New Quebec hires should receive the French-language version by default and only opt into another language with documented consent.
• Register for the OQLF's Francisation program if you employ 25 or more people in Quebec. Registration is mandatory for businesses with 25+ Quebec employees (Bill 96 lowered the threshold from 50). The OQLF can require a Francisation certificate or, for larger employers, a Francisation program demonstrating French is the working language.

OQLF guidance documents are publicly available and reasonably readable. Use them.

Penalties

Bill 96 increased fines significantly. The framework now includes:

• Administrative monetary penalties for individual violations
• Substantially higher fines for repeat offenders and corporations
• Civil remedies for affected employees and applicants, including damages
• Suspension or revocation of permits and contracts in some cases

The enforcement model also broadened the standing to file complaints. Employees, applicants, and the OQLF itself can initiate proceedings. In practice, much of the enforcement is complaint-driven — a single dissatisfied applicant or terminated employee can put your French-language compliance on the OQLF's desk.

Bill 96 vs. Law 25: two regimes, both apply

A common confusion: Bill 96 and Law 25 are sometimes treated as the same Quebec compliance topic. They are not.

• Bill 96 is about the language of work, services, and documentation in Quebec. The regulator is the OQLF.
• Law 25 (the modernized Quebec private-sector privacy law) is about personal information — collection, consent, retention, breach reporting, cross-border transfers. The regulator is the Commission d'accès à l'information (CAI).

Both apply to your Quebec operations independently. A Quebec offer letter that is in proper French (Bill 96 compliant) but signed and stored in a system that does not meet Law 25's privacy obligations is half-compliant. Build both into your Quebec onboarding flow. For the privacy side, see our PIPEDA primer and the Quebec Law 25 PIA template.

What to do this quarter if you have Quebec employees

A short list:

• Pull your three most-used HR templates (offer letter, performance review, disciplinary letter) and confirm a current French version exists, drafted by a francophone legal professional.
• Audit your last 10 job postings for Quebec roles. Were any posted English-only? Did any require non-French language without documented justification?
• If you have 25+ employees in Quebec, confirm OQLF Francisation registration is in place.
• Cross-link with your Law 25 work. The same legal counsel who advises you on Bill 96 likely also advises on Law 25 — bundle the conversation.

For the offer-letter template work specifically, our job offer letter template covers the structural choices, and you'll want a francophone counsel to handle the Quebec-specific French version.

WalnutsHR's roadmap includes a French-language interface as a near-term priority — the documentation you store in WalnutsHR doesn't help if your Quebec employees can't read the system in their own language. Until that ships, the practical compliance focus is on the documents themselves.

Need to get your Quebec onboarding workflow on solid ground? Start with WalnutsHR free and consolidate the documentation in one place while you tackle the translation work.