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

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
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
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
  1. Law 25 data portability right takes effect
  2. Most Law 25 provisions take effect, including consent, transparency and administrative monetary penalties of up to $10 million or 2% of worldwide turnover
  3. First Law 25 provisions take effect (person in charge, confidentiality incidents, biometrics disclosure)

Amendments

  1. 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

  2. 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

  3. 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

  4. 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

  1. Law text Act respecting the protection of personal information in the private sector (CQLR c. P-39.1)
  2. Law text An Act to modernize legislative provisions as regards the protection of personal information (S.Q. 2021, c. 25, as assented)
  3. Guidance Principaux changements apportés par la Loi 25 (CAI)
  4. 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)