Québec HR compliance in 2026: your guide to what's in effect and what's ahead

Key Takeaways

Québec employers are navigating one of the busiest compliance periods in recent memory, with multiple legislative changes already in force, a major occupational health and safety deadline approaching in October 2026, and further proposed regulations in progress. This article breaks down what's already in effect, what's coming, and what you need to do to stay on the right side of the rules.

In this article:

1. What Québec employment law changes are already in effect?
2. What Québec employment law changes are still coming?
3. How to stay on top of it all
   

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For Québec employers, 2025 and 2026 have brought lots of legislative changes. From new restrictions on sick notes and a mandatory harassment policy to a minimum wage increase and a looming occupational health and safety deadline, there's a lot on the compliance calendar right now -and some of it is already in effect.

We'll be covering the following to help you get a solid grasp on what's changed and what's ahead:

• What Québec employment law changes are already in force, including sick note restrictions, a mandatory psychological harassment policy, a minimum wage increase, and new occupational health and safety requirements that came into effect in late 2025.
• What's still coming, including the October 6, 2026 deadline for occupational health and safety prevention programming, proposed sexual violence prevention training requirements, and enhanced penal sanctions.
• How to stay on top of it all with our Québec HR compliance checklist.

What Québec employment law changes are already in effect?

Several significant changes are already in force for Québec employers. Here's what you need to know:

Can Québec employers request a sick note for short-term absences?

Since January 1, 2025, Québec employers may no longer request any documentation - including a medical certificate - to justify an employee's first three short-term absences (each of three consecutive days or fewer) within a rolling 12-month period. This applies to absences caused by illness, accident, organ donation, domestic violence, sexual violence, or a criminal offence. As well, employers can never require a medical certificate when an employee is absent to care for a child, family member, or someone they act as a caregiver for.

This comes from Bill 68, which amended the Loi sur les normes du travail (Act Respecting Labour Standards). The Commission des normes, de l'équité, de la santé et de la sécurité du travail (CNESST) has more information on absences for illness and family obligations.

If your absence policies still include language requiring documentation for short absences, now is the time to update them!

What are Québec employers required to do about psychological harassment?

Since October 1, 2025, all Québec employers must have a written policy to prevent and manage psychological harassment in the workplace. The policy must include a description of prohibited conduct, a complaints process, protection against reprisals, and references to available training. It must also explicitly cover harassment from any person, including clients, contractors, and suppliers, not just colleagues.

Fines for non-compliance were significantly increased under Bill 42. If your organization doesn't yet have a written harassment policy that meets these requirements, this needs to be a near-term priority.

The CNESST has detailed guidance on psychological harassment obligations.

What OHS requirements are already in force under Bill 59?

Key provisions of Bill 59 (An Act to modernize the occupational health and safety regime) have been coming into force on a phased timeline since 2022, administered by the CNESST.

Among the provisions already in effect:

• Since September 27, 2024, employers no longer have direct access to a worker's medical records held by the CNESST in relation to a workers' compensation claim. Employers may only designate a health professional to receive a summary.
• Health and safety obligations for employers, including rules around designated H&S representatives in certain workplaces, have been rolling out across the phased implementation schedule

The CNESST's prevention program resources include current guidance on all in-force requirements.

What is the current minimum wage in Québec?

The general minimum wage in Québec increased to $16.60/hr effective May 1, 2026. A special lower rate applies to employees who customarily receive tips.

If you haven't already updated your payroll system and reviewed compensation for any affected employees, we encourage you to do so ASAP. The CNESST's minimum wage page has the current rates and the applicable tipped employee rate, which you can use as a resource.

What Québec employment law changes are still coming?

Beyond what's already in force, several significant developments are on the horizon for Québec employers:

What is the OHS prevention programming deadline for Québec employers?

The largest upcoming compliance deadline is October 1, 2026. Under the permanent provisions of Bill 59 and Bill 101, all Québec employers must have a documented occupational health and safety (OHS) prevention program (or action plan) in place by that date. No further extensions are expected, so get started building your prevention program or action plan if you haven’t already!

What's required depends on your team size:

• Employers with 20 or more workers must have a formal written prevention program that identifies and addresses all workplace risks -physical, chemical, biological, ergonomic, and psychosocial (including harassment) - plus an established health and safety committee.
• Employers with fewer than 20 workers must implement a documented action plan that covers the same categories of risk.

The CNESST has step-by-step prevention program resources to help you get started.

What are the proposed requirements around sexual violence prevention in Québec workplaces?

In October 2025, Québec tabled a draft regulation on measures to prevent or address sexual violence in the workplace. If adopted as drafted, all employers would be required to provide sexual violence prevention training to all employees (renewed every three years, delivered by a qualified person), establish a formal complaint and reporting process, and designate a competent, impartial person to handle cases. As of the time of writing this article, a final version has not been confirmed. Watch for the final regulation and any associated transition period.

Note that your psychological harassment policy - already mandatory since October 1, 2025 - must include training references under existing Bill 42 requirements. Pro tip: Reviewing and updating that policy now will put you in a stronger position when the final sexual violence regulation is released.

The CNESST's prevention and safety page will be updated as the final regulation is released.

Do Québec's French-language obligations apply to my business?

Since June 1, 2025, the francization threshold under Bill 96 (Charter of the French Language) dropped from 50 to 25 employees. Employers with 25 or more Québec-based employees must now register with the Office québécois de la langue française (OQLF; link in French only), conduct a workplace linguistic analysis, and — if French is not used at all levels — develop and implement a francization program.

Separately, all Québec employers, regardless of size, must issue job postings, employment contracts, internal communications, and onboarding documents in French. Employees have the right to work in French and cannot be required to know another language as a condition of employment or promotion unless the nature of the role demonstrably requires it.

The OQLF's francization resources cover registration and program requirements.

How have penalties changed for Québec labour standards violations?

Bill 101 (in force October 28, 2025) significantly increased fines under both the Code du travail and the Loi sur les normes du travail. It replaced both minimum and maximum penalties, doubles fines for a second offence, and triples fines for subsequent offences.

If your HR policies and payroll practices haven't been reviewed for compliance recently, the higher penalty scale is a good reason to check that off your to-do list.

Has the LMIA fast-track list changed for Québec employers?

Yes. In February 2026, the province of Québec reduced the number of eligible occupations on the Labour Market Impact Assessment fast-track list from 76 to 60. If you've been using the fast-track process for occupations that are no longer on the list, you'll need to post recruiting ads for those roles going forward.

Check the updated list of eligible occupations on the Québec government website (link in French only) and adjust your hiring timelines accordingly.

Frequently asked questions

Does Québec have its own employment standards body, separate from the federal government?

Yes. Québec’s employment standards, pay equity, and workplace health and safety are all administered by a single provincial body: the CNESST (Commission des normes, de l’équité, de la santé et de la sécurité du travail). Most Québec employers are regulated provincially, not federally, which means the rules in this article apply to the vast majority of Québec workplaces. Federally regulated employers - those in banking, telecommunications, interprovincial transport, and similar industries - fall under the Canada Labour Code and are subject to a separate set of obligations.

What is the October 6, 2026 OHS deadline, and what happens if we miss it?

October 6, 2026 is the deadline by which all Québec employers must have a documented occupational health and safety (OHS) prevention programme (for workplaces with 20 or more workers) or a written action plan (for workplaces with fewer than 20 workers) in place. This requirement comes from Bill 59, Québec’s most significant overhaul of workplace safety legislation in decades. Employers who are not compliant by the deadline face CNESST inspections and enforcement, including orders to comply and potential fines. Important to note: no further extensions to this deadline are expected.

Do Québec’s French-language obligations apply to employers outside Québec?

The Charter of the French Language (Bill 96) applies to employers based in Québec and to employers outside Québec who have employees working in the province. If you have employees in Québec (whether in-office or remote) you are subject to Québec’s French-language obligations. That means employment contracts, job postings, internal communications, and onboarding documents must be provided in French. If you have 25 or more Québec-based employees, the expanded francization obligations under Bill 96 also apply to you, including registration with the OQLF and a workplace linguistic analysis.

Where can Québec employers find official information on their compliance obligations?

The CNESST is the primary source for employment standards, pay equity, and occupational health and safety in Québec. LégisQuébec publishes the full text of all consolidated provincial statutes and regulations in both French and English. For parental insurance premiums and rates, RQAP and Revenu Québec are the authoritative sources. For French-language obligations, the OQLF  is the relevant body. And for immigration and temporary foreign workers, MIFI governs the Québec side of the process. Links to each of these sources appear throughout this article. As always, for questions specific to your organization, a qualified employment lawyer practising in Québec is the right call.

Stay on top of it all

Join our HR Compliance in Quebec webinar to help you understand how Payworks HR supports your compliance workflows, from storing and distributing policy documents with e-signature tracking to managing absence entitlements and keeping your payroll current with the latest Québec rates. Register Now (link in French only).