Bill 96 in its Final Form: Essential Insights and Compliance Strategies
Key Takeaways
Employment agreements must be provided in French first, with limited exceptions for individually negotiated contracts. Most written internal communications must also be in French unless an employee formally requests otherwise.
Companies with 5+ Quebec employees must file language disclosures. OQLF registration becomes mandatory at 25 employees starting June 2025.
Organizations must offer internal software in French if a French version exists. Websites, regardless of software availability, must be accessible in French.
The exemption for English trademarks only applies to registered marks that reflect the product's name. Descriptive or generic content must be translated.
Contracts of adhesion can only be signed in another language if both parties review the French version first. In-house counsel must manage this process and ensure accurate reporting of linguistic capabilities during corporate filings.
Why should lawyers revisit Bill 96 now?
The final version of the regulation, in effect since June 2024, introduces stricter compliance requirements. Lawyers advising clients in Quebec must understand these changes to mitigate risk. Resources to help you do so can be found on our Bill 96 learning hub.
What new obligations do in-house counsel need to prioritize?
Employment contracts in French, REQ language disclosures, and compliance with the June 2025 francization threshold are among the most urgent.
How is trademark use affected by the final version of Bill 96?
Only registered trademarks may appear exclusively in English. Any descriptive or generic wording must be translated into French, regardless of branding.
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