Quebec's Law 25: What Every Business Must Know (2026)

What Is Quebec’s Law 25?

Quebec’s Law 25, formally titled the Act to Modernize Legislative Provisions as Regards the Protection of Personal Information, is the province’s landmark privacy reform. Originally introduced as Bill 64 in 2020 and passed in September 2021, it overhauled the rules governing how private-sector organizations collect, use, store, and share personal information about Quebec residents.

As of 2026, every phase of Law 25 is fully in effect. There are no grace periods remaining. Any organization that handles the personal data of Quebec residents, whether based in Montreal, Toronto, or San Francisco, must comply or face significant financial and reputational consequences.

Why Law 25 Matters: The Scope Is Broader Than You Think

Law 25 applies regardless of where your organization is incorporated or headquartered. If you collect, use, or disclose personal information about people residing in Quebec, the law applies to you. This includes:

E-commerce stores serving Quebec customers
SaaS companies with Quebec user accounts
Marketing agencies collecting visitor data from Quebec-based websites
HR platforms processing data about Quebec employees

There is no size threshold. A three-person startup and a multinational corporation face the same core obligations. Quebec’s law is considered the strictest provincial privacy regulation in Canada, going further than the federal Personal Information Protection and Electronic Documents Act (PIPEDA) in several areas.

Core Obligations: What Law 25 Actually Requires

1. Appoint a Privacy Officer

Every organization subject to Law 25 must designate a person responsible for personal information protection (PRPI), often called a privacy officer or data protection officer. This person’s name and contact information must be publicly available, typically on your website’s privacy policy page. The PRPI oversees breach reporting, data subject requests, and internal governance.

2. Obtain Explicit, Granular Consent

Generic privacy notices bundled into terms of service no longer meet the standard. Consent under Law 25 must be:

Free, meaning not coerced by withholding access to a service
Informed, meaning written in plain language with a clear explanation of purposes
Granular, meaning given separately for each distinct use of personal data
Revocable, meaning withdrawal must be as easy as granting consent

This directly affects your website’s cookie consent banner, email subscription flows, and any form collecting personal information.

3. Implement a Compliant Cookie Consent Banner

Quebec Law 25 mandates an opt-in model for tracking technologies. Non-essential cookies, analytics scripts, advertising pixels, and similar trackers must be turned off by default. They may only activate after the user explicitly consents. Pre-ticked boxes, dark patterns, or “continue browsing equals consent” approaches do not comply. Your consent management platform must document each user’s consent and make withdrawal available at any time.

4. Publish a Transparent Privacy Policy

Your privacy policy must explain, in accessible language, what personal information you collect, why you collect it, how long you retain it, who you share it with, and how residents can exercise their rights. The policy must be easy to find, not buried in a footer link that leads to a wall of legal text.

5. Conduct Privacy Impact Assessments (PIAs)

Before launching any project that presents a significant risk to personal information, you must complete a Privacy Impact Assessment. This includes deploying new marketing analytics tools, integrating AI-powered personalization, transferring data to third-party vendors, and moving data outside Quebec. PIAs must be documented and, in certain cases, shared with the Commission d’acces a l’information (CAI).

6. Manage Data Breach Notifications

If a confidentiality incident occurs, organizations must assess the risk of serious injury to affected individuals, notify the CAI without delay when there is a risk of serious injury, and notify affected individuals directly. A register of all confidentiality incidents must be maintained, even those that do not meet the notification threshold.

7. Honour Individual Rights

Quebec residents now have the following enforceable rights:

Right of access: Receive a copy of their personal information you hold
Right of rectification: Correct inaccurate data
Right to erasure and de-indexation: Request deletion of data collected unlawfully or no longer necessary
Right to data portability: Receive their information in a structured, machine-readable format and have it transferred to another organization (in effect since September 2024)
Right to challenge automated decisions: Request human review of decisions made exclusively by algorithm

Law 25 and Artificial Intelligence: A Growing Compliance Layer

AI-driven tools are now embedded in marketing stacks across every industry, and Law 25 specifically addresses them. Section 12.1 requires organizations to disclose when a decision affecting an individual is made exclusively through automated processing. You must explain the logic involved and the potential consequences.

This applies to hiring algorithms, dynamic pricing engines, AI-powered lead scoring, personalization systems, and any tool that profiles Quebec residents to make automated decisions about them. Privacy Impact Assessments are mandatory for high-risk AI processing. Consent for AI-driven data use must be explicitly stated, not buried in a general privacy notice.

Organizations relying on U.S.-based AI platforms also face added scrutiny under cross-border transfer rules (Section 17). Transferring data outside Quebec requires confirming that the receiving jurisdiction provides adequate protection, and the U.S. CLOUD Act creates genuine compliance complexity. Canadian data residency offers a cleaner path.

Penalties: The Stakes Are Real

The CAI operates a two-tier penalty framework:

Administrative penalties: Up to $10 million CAD or 2% of worldwide annual turnover, whichever is higher
Penal fines: Up to $25 million CAD or 4% of worldwide annual turnover, whichever is higher, with a minimum of $15,000 for corporations

Repeat violations double the fine. The CAI can also require organizations to publicly disclose violations, which compounds reputational damage beyond the financial hit. Enforcement is active in 2026, with emerging case law shaping how the CAI interprets compliance obligations in practice.

A Practical Compliance Checklist for 2026

Privacy officer appointed and name published on your website
Cookie consent banner using opt-in defaults, with granular purpose categories
Privacy policy updated for Law 25 language requirements, accessible in French and English
Process in place for handling data subject requests within the required timeframe
Data breach notification procedure documented and tested
PIAs completed for all high-risk data processing activities, including AI tools
Third-party vendor contracts reviewed for data processing clauses
Cross-border data transfer documentation in place for any U.S. or international tools
Automated decision-making disclosures integrated into user-facing communications

Quebec’s Law 25 was directly inspired by Europe’s General Data Protection Regulation (GDPR), and the two share many structural similarities: explicit consent, data subject rights, breach notification, and privacy impact assessments. However, Law 25 goes further in one notable area: the right to de-indexation, which allows Quebec residents to request that search engines remove links to web content about them if the information was collected without valid consent. Law 25 also includes a specific right to data portability directed at third-party transfers, not just individual access, which has no direct GDPR parallel.

If your organization is already GDPR-compliant, you are well positioned, but a gap analysis specific to Law 25 is still necessary. The two regimes are not identical.

Start With Your Website

For most businesses, the fastest visible exposure is on their website: a cookie consent implementation that doesn’t meet opt-in standards, a privacy policy written before 2022, or analytics tools firing before user consent. These are the issues the CAI can identify through routine monitoring, and they are also the easiest to fix with the right partner.

At Index Web Marketing, we help businesses audit their data collection practices, configure compliant consent management, and align their analytics infrastructure with Law 25 requirements. If you are unsure where your current setup stands, a compliance audit is the right first step.

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– **All facts verified** against 2026 sources including BLG (Feb 2026), Augure AI, CAI penalty framework, and cookie consent requirements

Sources:
– [Quebec Law 25 AI Compliance: The Complete 2026 Guide | Augure](https://augureai.ca/blog/law-25-ai-compliance-guide-quebec)
– [Québec Private Sector Act: Compliance guide for organizations | BLG](https://www.blg.com/en/insights/2026/02/quebecs-private-sector-act-compliance-guide-for-organizations)
– [Quebec Law 25: obligations, deadlines and compliance (2026 guide) | DPLIANCE](https://dpliance.com/en/blog/quebec-law-25/)
– [Quebec Law 25 Cookie Consent 2026 | CookieBeam](https://cookiebeam.com/guides/quebec-law-25-cookie-consent-2026)
– [Law 25 enforcement scheme | Osler](https://www.osler.com/en/insights/updates/law-25-a-new-enforcement-scheme-for-protection-of-personal-information-in-the-private-sector-in-que/)
– [Right to data portability | Osler](https://www.osler.com/en/insights/updates/completing-the-law-25-puzzle-insight-into-the-right-to-data-portability/)

Quebec’s Law 25: What Every Business Must Know (2026)