Bill 96 and Quebec's language charter, explained for localization agencies

What to take away

What Bill 96 changed in the Charter of the French Language

Bill 96 is the short name for An Act respecting French, the official and common language of Quebec, assented to on June 1, 2022. It amended the Charter of the French Language, the statute also known as Bill 101 and cited as CQLR c C-11. The Charter still governs the use of French in Quebec commerce, workplaces, signage and public services.

Bill 96's obligations came into force in stages, on June 1 of 2022, 2023, 2024 and 2025. The stage that pulls most Quebec scopes into the regime is June 1, 2023, when businesses with 25 to 49 employees took on the francisation duties larger employers already carried. The final stage, June 1, 2025, closed the transition period for non-French trademarks on storefronts, packaging and public signage.

The OQLF publishes the consolidated Charter text, and that is the version to read before quoting a client. Its legislative changes page tracks each amendment and its coming-into-force date, which is where the staged dates above come from. A timeline copied from a 2022 summary will be wrong on at least one obligation.

The amendments pulled more businesses into scope, tightened commercial signage and contract rules, and added duties around customer service and information technology. French stopped being a marketing preference for a Quebec-facing brand. It became a condition of trading in the province.

One number decides most scoping calls. A business with 25 to 49 employees carries duties that a business with 24 does not. Ask for the headcount before you ask for the word count.

Contracts of adhesion, the take-it-or-leave-it kind used with consumers and some suppliers, must be presented in French unless the parties agree otherwise. Agencies that hand Quebec clients their own template agreements should expect those templates to be read for French-language compliance.

Trademark and signage rules changed under a transition period that ended on June 1, 2025. The Regulation respecting the language of commerce and business governs commercial signs and advertising, and it generally requires a French descriptor beside a non-French mark on a storefront or a package. That work lands with the terminology team, because choosing the descriptor is a language decision, not a translation one.

The OQLF also gained stronger investigative powers. It can request documents, interview staff and inspect premises. An agency that keeps dated project records is easier to defend than one that reconstructs decisions after a complaint arrives.

Which businesses and localization providers fall under OQLF francisation duties

Francisation means making French the normal working language of a business. The OQLF's business francisation page lists the obligations and the registration steps. Duties scale with headcount, so confirm the threshold with every Quebec client before you scope.

At 25 or more employees, a business registers with the OQLF on the office's francisation registration form within three months of crossing the threshold, and forms a francisation committee. The committee reports on the state of French in the business, and the business files a francisation plan within six months of registering, then files progress reports. The plan covers workplace communication, hiring, training, customer service and the language of internal documents. The headcount that starts both clocks is the one the business declares in its Registraire des entreprises (REQ) annual update, so keep that filing current.

At 50 or more employees, further requirements apply, including a francisation certificate in some cases. The OQLF grants certification after reviewing the plan and its results, and the business keeps reporting afterwards. It is a maintained status, not a one-time badge.

A localization agency sits on both sides of this system. As a Quebec employer it may owe francisation duties itself. As a supplier it sells the translation, terminology and adaptation work that helps clients meet theirs. Both roles deserve a look before you sign a Montreal localization contract.

An agency outside Quebec is not exempt when it serves Quebec clients. The Charter follows the business activity in Quebec, not the vendor's head office. A Toronto or Vancouver agency localizing a Quebec retail site supplies a deliverable the client must be able to defend.

Subcontractors feed into the same record. Work passed to a freelance translator becomes part of the client's francisation file. That is one reason to fix translation agency intake before a new account goes quiet: the intake form should capture the client's francisation status, employee count and any open OQLF file.

Public bodies carry language duties on top of the Charter's business rules. Under the Charter's rules for the civil administration, government departments and agencies, municipalities, school service centres and health and social services institutions must serve the public in French regardless of headcount. Ask which regime applies before you price that work.

OTTIAQ certification and what it means for Quebec contracts

The Ordre des traducteurs, terminologues et interprètes agréés du Québec, known as OTTIAQ, is the professional order for translators in the province. Members hold a reserved title and answer to a code of ethics. The OQLF lists the professional orders it works with, which is the page to send a client who asks why certification matters.

Certification means the translator met the order's admission requirements and is subject to its discipline. On a regulated or public contract, that credential often decides who can bid. Some Quebec solicitations require certified translators for official documents, court material and certified translations.

Certification is not a translation degree, though the two overlap. It is a professional designation with continuing education and ethics obligations attached. A client asking for a certified translator is usually asking for a signature and seal a public body will accept.

The staffing question follows. If a contract needs certified translations, the work goes to an OTTIAQ member or to a member of a body covered by a mutual recognition arrangement. Confirm the requirement before you quote a rate, not after.

Certification also changes how you budget revision. A certified translator can revise and sign off on a text, which is a different job from a bilingual employee reading a draft. When a contract calls for certified revision, budget a qualified reviser rather than a second pass by the original translator.

An agency with a bench of OTTIAQ members in Montreal and Quebec City answers those requests in a day. That bench also sharpens how you compare contract terms against what actually happens when quality or liability is disputed.

Worked example: a Montreal retail brand localizing into French

A Montreal clothing brand with 60 employees sells online and through three stores. It falls under the Charter, registers with the OQLF and needs a francisation plan. Its agency handles the website, product names, in-store signage and staff training material.

The agency scopes in three phases: the ecommerce catalogue and checkout flow, then signage and packaging, then internal documents and the store training deck. Each phase carries its own terminology decision log.

Product names are the hard part. Some are trademarks that stay in English with a French descriptor. Others are descriptive and need a French equivalent. The agency keeps a bilingual glossary recording why each name was kept or changed, because the client may have to explain those choices to the OQLF.

Customer service scripts are localized too. The brand must serve customers in French, and the scripts are part of that duty. The agency delivers them with a short staff guide, which lowers the chance a French-speaking customer is answered in English.

The contract carries a clause on ongoing updates. New products and promotions need French versions before launch, not after. The agency sets a service level for catalogue updates and a monthly terminology review, which stops the client accumulating a backlog that reads as non-compliance.

The agency also documents the francisation support it gave. The file lists deliverables, reviewers, dates and the certification status of each translator. If the OQLF asks the brand how it meets its duties, that file is the answer.

Worked example: a Quebec City public body buying localization projects

A Quebec City public body tenders for translation and adaptation of citizen-facing material: forms, guides, web pages and public notices. The tender shows how the Charter and public procurement rules meet.

French is the primary language of the deliverables, with English versions for specific audiences. Translators must belong to a recognized professional order, which points to OTTIAQ certification or a recognized equivalent.

The body asks for a terminology bank as a deliverable, reusable by its own staff. That changes the pricing model. The agency is selling a maintained asset rather than a batch of documents.

Each delivery carries a compliance statement confirming source language, target language, translator credentials and revision date. It is a short document that settles arguments later.

The lesson is to price the governance work, not only the words. Terminology maintenance, version control and compliance statements consume hours. Agencies that treat them as overhead tend to lose money on public contracts. If you are weighing this work against private-sector accounts, it helps to know which markets suit a translation agency before you commit.

Compliance risk from OQLF complaints and non-conformity lists

The OQLF investigates complaints and denunciations about language use, and its complaints page explains the process. A complaint can come from a customer, an employee or a competitor.

The office can request information, inspect a business and issue findings. It can also refer an offence for prosecution, and the Charter sets fines for businesses that do not comply. A non-compliant business can be named on a published list, which turns a language lapse into a searchable reputational event.

For an agency the risk is indirect but real. An incomplete French site or wrong signage can put the client on that list, and your work becomes part of the story even when a missed deadline or a scope cut caused it.

Contractual risk follows. A client facing a complaint looks for someone to share the cost. If the contract does not say who owns terminology decisions, who approves final copy and what happens when deadlines slip, the agency can be pulled into a dispute it did not create.

Keep records of the advice you gave. If a client declined a French version of a page, note it. If a client insisted on a trademark treatment, note it. Records do not prevent complaints, but they change the conversation when one arrives.

Check your professional liability cover as well. Some policies treat language compliance work differently from general translation. Confirm coverage before taking on a francisation plan for a client with a large public presence.

How agencies document francisation for clients

Documentation is the difference between a smooth OQLF review and a scramble. The agency's job is a file the client can hand over on request: complete, dated and easy to read.

Open with a project charter naming the client's francisation obligations and the deliverables that support them. Then keep three logs: terminology, decisions and revisions. Together they answer most questions about why a text reads the way it does.

Run this checklist on every delivery so the file looks the same whoever manages the project: the signed project charter; the client's francisation obligations, headcount and any OQLF file reference; the bilingual terminology log; the decisions log with the reason for each choice; the revision log with the named reviser; the certification status of every translator who signed off; and the dated compliance statement for each delivery.

When a client asks how the process runs, a short sequence beats a long manual.

Documentation also sells. It fits naturally into what to put in a translation agency package, because a client can see the file and keep it.

Review the file at renewal. Francisation obligations change as a business grows, and a client with 20 employees last year may have 30 now. Update the documentation when the threshold moves, not after a complaint. If you are planning new accounts or regions, translation agency expansion under review is worth reading alongside this work.

Common questions

Does Bill 96 apply to an agency based outside Quebec?

Yes, when the agency serves Quebec clients or operates in the province. The Charter follows the business activity in Quebec, not the vendor's head office. Your client's francisation duties flow into the deliverables you supply.

What is the employee threshold for OQLF francisation duties?

Registration and a francisation committee start at 25 employees. Businesses with 50 or more face further requirements, including certification in some cases. Confirm the current rules on the OQLF business francisation page before you quote.

Do I need OTTIAQ certification to translate for Quebec clients?

Not for every job, but many public and regulated contracts require it. Certification gives the client a credential it can point to. Keep a bench of certified translators for those contracts.

What happens if a client is named on a non-conformity list?

The OQLF can publish the names of non-conforming businesses, which is a public reputational risk. Good project records help the client respond and show what the agency advised. Keep those records for the life of the relationship and past the limitation period in your contract.