Bill 96: Quebec’s French Language Law and the Life Insurance Industry

June 16, 2023 at 8:57 AM / by John Allen, Regulatory Compliance Counsel, APEXA  /  3 minute read


Efforts to protect French language rights in Quebec date as far back as the 1800s, and since 1974, French has been the only official language in the province. Recently, the government has bolstered their work to promote use of French in Quebec. In May of 2022 the National Assembly of Quebec adopted Bill 96, An Act respecting French, the official and common language of Quebec, which received royal assent on June 1, 2022, and is intended to affirm that the only official language of Quebec is French.

Bill 96 modifies over 25 legislations, including the Charter of the French Language (the Charter) 1977, the Constitution Act of 1867, the Charter of Human Rights and Freedoms, and the Civil Code of Québec. It introduces several measures around the use of French in commerce, labor relations and contracts that have direct impact on business, including the life insurance industry.

Among these are a requirement that: 

  • Employers must “take reasonable means” to avoid requiring knowledge of a language other than French as a condition of employment. Effective June 1, 2022
  • Consumers in Quebec, including business clients, have the right to be informed and served in French by businesses. This has implications for marketing and advertising as well as sales and service touch points. Effective June 1, 2022
  • Written documents submitted to government agencies (permits, authorizations etc.) must be exclusively in French. Effective June 1, 2023
  • Trademarks on public signs and in commercial advertising in Quebec must be translated to French, including common law trademarks and pending and unregistered trademarks (some exceptions apply). Effective June 1, 2023
  • When advertising in exterior spaces in Quebec, French text that accompanies a non-French registered trademark must be “markedly predominant” in comparison to the trademark. Effective June 1, 2023

Of particular impact to APEXA users is an obligation that became effective June 1, 2023, regarding contracts of adhesion (legal contracts where the agreements terms are defined solely by the issuing party). Bill 96 includes an obligation to draft contracts of adhesion in French. Such contracts may only be drafted in a language other than French if, AFTER a French version has first been remitted to the client, the client has expressed their wish to be bound by the contract in another language. 

What this means is that carriers and MGAs will need to default to providing contracts to advisors in Quebec in French first. In order to ensure a binding contract, advisors in Quebec will need to affirmatively express a desire to be bound by a version in a language other than French. 

While APEXA is not directly a party to these agreements, our platform does facilitate the digital contracting process. As such, APEXA is making changes to our system that will help carriers, MGAs and advisors comply with this aspect of Bill 96. Starting in June 2023, you will notice some differences in our system that support this effort.

These legislative changes have a direct effect on the way business is conducted in Quebec. We at APEXA recognize the disruption that these regulatory changes may bring, and the associated potential for frustration. As the advisor contracting platform for the Canadian Life Insurance industry, we remain committed to helping make the contracting process as efficient as possible, while also remining complaint with emerging legislative and regulatory requirements.

Please note: The information provided in this post does not, and is not intended to, constitute legal advice; nor is it a comprehensive description of Bill 96 nor its potential impact on your business. Instead, all information in this post are for general informational purposes only. We encourage you to contact your own legal counsel to obtain advice with respect to any particular legal matter. 



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