Quebec Law 25
Act to modernize legislative provisions as regards the protection of personal information (S.Q. 2021, c. 25), amending the Act respecting the protection of personal information in the private sector (CQLR c. P-39.1) — National Assembly of Quebec / CAI (Commission d'accès à l'information du Québec)
Also known as: Law 25, Loi 25, Bill 64, P-39.1, Quebec privacy act
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At a glance
- Current version
- Not confirmed by an official source yet.
- Status
- In force
- Next deadline
- None announced
- Who must comply
- Any person carrying on an enterprise in Quebec that collects, holds, uses or communicates personal information about others, whether it keeps the information itself or through a third person. source
- How it is assessed
- Enterprises name a person in charge, assess privacy impacts of new systems and transfers, and report serious confidentiality incidents to the CAI. source
- Authority
- Enacted by the National Assembly of Quebec; the Commission d'accès à l'information (CAI) oversees it, imposes administrative monetary penalties and can bring penal proceedings. source source
- Enforced by
- The CAI can impose administrative monetary penalties and bring penal proceedings, and courts award punitive damages for intentional or grossly negligent infringements. source
- Last change
- None recorded yet
Quebec's private-sector privacy regime, rebuilt by Law 25. It reaches any organisation holding personal information about people in Quebec and goes further than the federal act: a named privacy officer, mandatory confidentiality incident reporting, privacy impact assessments before transferring information outside Quebec, data portability, and administrative penalties large enough to make it the sharper of the two Canadian regimes.
Recent changes
No changes recorded yet — we are watching, and nothing has been published.
Key dates
No upcoming dates- Law 25 data portability right takes effect
- Most Law 25 provisions take effect, including consent, transparency and administrative monetary penalties of up to $10 million or 2% of worldwide turnover
- First Law 25 provisions take effect (person in charge, confidentiality incidents, biometrics disclosure)
Amendments
-
Law 25, final stage (data portability) Amendment
The right to receive computerised personal information in a structured, commonly used technological format took effect, completing Law 25's three-year rollout. source
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Law 25, second stage Amendment
Most of Law 25 took effect, including new consent and transparency rules, privacy impact assessments before communicating information outside Quebec, and administrative monetary penalties. source
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Law 25, first stage Amendment
First provisions took effect: a person in charge of personal information, confidentiality incident reporting and register, prior disclosure of biometric identity checks, and rules for communication in commercial transactions and research. source
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Law 25 (S.Q. 2021, c. 25) assented to Major version
Act to modernize legislative provisions as regards the protection of personal information (Bill 64), passed on 21 September 2021, assented to on 22 September 2021 and phased in over three years. source
Who it applies to
The Act covers personal information handled by any enterprise in Quebec, in any medium, with an exception for journalistic, historical or genealogical material.
- Enterprises
- Personal information that a person collects, holds, uses or communicates in the course of carrying on an enterprise within the meaning of article 1525 of the Civil Code (section 1). source
- Any medium
- It applies whether the enterprise keeps the information itself or through a third person, and whatever its medium or form (section 1). source
- Excluded
- Journalistic, historical or genealogical material collected, held, used or communicated for the legitimate information of the public (section 1). source
- Outside Quebec
- Before communicating personal information outside Quebec, the enterprise must conduct a privacy impact assessment (section 17). source
How compliance is assessed
Enterprises name a person in charge, assess privacy impacts of new systems and transfers, and report serious confidentiality incidents to the CAI.
- Person in charge
- The person with the highest authority is in charge of protecting personal information, may delegate in writing, and the title and contact details must be published on the website (section 3.1). source
- Privacy impact assessment
- Required for any project to acquire, develop or overhaul an information system or electronic service delivery system involving personal information (section 3.3). source
- Confidentiality incidents
- Promptly notify the CAI and affected persons of an incident presenting a risk of serious injury (section 3.5), and keep a register of all incidents (section 3.8). source
- Portability
- On request, communicate computerised personal information collected from the person in a structured, commonly used technological format (section 27). source
Enforcement and penalties
The CAI can impose administrative monetary penalties and bring penal proceedings, and courts award punitive damages for intentional or grossly negligent infringements.
Up to $10M or 2% of worldwide turnover
Administrative monetary penalty (section 90.12), for example for failing to report a confidentiality incident or to take necessary security measures; up to $50,000 for a natural person. source
$15,000 to $25M or 4% of worldwide turnover
Penal fine (section 91), for example for unlawful collection or use, failing to report an incident or re-identifying de-identified information; $5,000 to $100,000 for a natural person, doubled for a subsequent offence (section 92.1). source
- Penalty power
- Since 22 September 2023 the CAI can impose administrative monetary penalties on enterprises, under a published general framework. source
- Undertakings
- A person in default may enter into an undertaking with the CAI to remedy the failure; if accepted and complied with, no penalty is imposed for those acts (section 90.1). source
- Punitive damages
- Where an unlawful infringement causes injury and is intentional or results from gross fault, the court awards punitive damages of at least $1,000 (section 93.1). source
Documents
- Law text Act respecting the protection of personal information in the private sector (CQLR c. P-39.1)
- Law text An Act to modernize legislative provisions as regards the protection of personal information (S.Q. 2021, c. 25, as assented)
- Guidance Principaux changements apportés par la Loi 25 (CAI)
- Guidance Sanctions administratives pécuniaires - general framework (CAI)
Frequently asked questions
What are the penalties under Quebec Law 25?
Administrative monetary penalties of up to $10 million or 2% of worldwide turnover, whichever is greater, and penal fines of $15,000 to $25 million or 4% of worldwide turnover for enterprises, doubled for a subsequent offence. source
When did Law 25 come into force?
In three stages: 22 September 2022, 22 September 2023 (most provisions, including penalties) and 22 September 2024 (data portability). source
Verified against official sources on 18 October 2026. We monitor the official sources for this framework. Watching since 20 September 2026. Subscribe to Quebec Law 25 (RSS)