Bill 96 and bilingual business plans in Quebec, a compliance guide

What to take away

What Bill 96 changed for commercial documents in Quebec

Bill 96 received assent on June 1, 2022 and phased in the commercial rules over the following three years. The core commercial-document duties, including a French version of contracts of adhesion, applied from June 1, 2023. The trademark rules for public signage and advertising took effect on June 1, 2025.

For a founder writing a business plan, the practical change is this: French is the default language of commercial documents in Quebec, and your plan is a commercial document when it circulates to customers, staff or investors here.

Commercial documents include contracts, invoices, receipts, signage and websites. If you offer a version in another language, the French version must be available and of at least equal quality. That means no English-only investor deck handed to a Montreal angel without a French counterpart.

A plan that describes your operations should also describe your language practice. State who drafts French copy, who reviews it, and how you handle a customer who asks for English. Regulators read intent, and so do investors. A plan that treats language as an afterthought reads as operational risk.

The Charter itself is the statutory basis for everything that follows, and you should cite it rather than paraphrase from memory: Charte de la langue française - Table des matières.

For the amending text and commencement, work from the official summary of changes rather than secondhand blog posts: Charte de la langue française - Changements législatifs.

If your plan includes a market entry section, the language rules belong in the operational part, not buried in an appendix. A reader checking plan fundamentals should see language compliance as a cost line and a control, like payroll or insurance. See plan fundamentals for how to keep one reader and one decision in view.

The Charter of the French Language and the OQLF's role

The Charter of the French Language sets out the rights and obligations around French in Quebec commerce, work and public life. The Office québécois de la langue française administers it, receives francisation registrations, issues attestations and investigates complaints.

In a business plan, the OQLF appears in two places. First, as a regulator you must satisfy if you employ staff in Quebec or sell to Quebec consumers. Second, as a body whose guidance shapes your document templates, hiring notices, software interfaces and marketing.

Describe your registration status plainly. If your enterprise is subject to francisation, say so. If you are exempt, say why. Investors in Quebec see this as a governance question, and lenders read it as a compliance cost.

The OQLF publishes its enterprise guidance directly, and the plan should reflect the current version: Entreprises francisation guidance.

Language obligations also touch how you describe ownership and control, because the Charter applies to enterprises carrying on business in Quebec regardless of where they are incorporated. A reader checking whether ownership is read twice will want the corporate structure and the language obligations to line up. That is covered in ownership is read twice.

Francisation obligations, committees and the Mémo assistant

Francisation is the process of making French the normal working language of an enterprise. Registration with the OQLF starts it, and the obligations scale with headcount and with the nature of your operations.

The Charter ties committee duties to headcount. An employer with 100 employees or more must form a francisation committee under the Charter's size test. Registration and francisation duties begin at 25 employees, lowered from 50 by Bill 96, in force since June 1, 2023.

The committee monitors the language situation, proposes an action plan and reports on progress. It is not decorative: the OQLF expects minutes, a plan and evidence of follow-through.

The Mémo assistant is the OQLF's tool for handling complaints and requests about language. Enterprises subject to the Charter use it to record and respond to complaints. In a business plan, name the person who monitors Mémo and the turnaround you commit to.

The language compliance summary page carries seven items:

Committee rules for larger enterprises are set out by the OQLF here: Francisation- Obligations des entreprises.

Structuring a bilingual plan: which sections are French-first

A bilingual plan is not two documents stapled together. It is one argument, with sections written French-first where the reader is a Quebec customer, employee or regulator, and bilingual where the reader is an investor or lender outside Quebec.

French-first sections are those that describe your Quebec operations: the executive summary for Quebec readers, the description of products and services, hiring and workplace language, customer service, and the compliance section. These should read as if written in French, then rendered into English, not the reverse.

Investor-facing sections can run in parallel columns or in paired pages: the financial model, the market estimate, the risk section and the use of funds. Keep the numbers identical across both versions. A mismatch between the French and English figures is the fastest way to lose a reader's trust.

Numbered steps for building the document:

Treat the executive summary as a decision document rather than a formality, because in a bilingual plan it is often the only page a regulator or investor reads first. The approach in executive summaries trends applies to both language versions.

A worked example shows how this reads in practice. Suppose a Montreal software firm with 120 employees sells to retailers across Quebec. Its operational sections are drafted in French first, and the investor pages run in both languages.

Its plan states that it registered for francisation in its first year of hiring, that its committee meets quarterly, and that Mémo complaints are answered within five working days. The firm expects certification within two years.

The English investor version repeats the same facts. Nothing is claimed that the OQLF file does not support.

Certified enterprises, particular agreements and the non-compliance list

Certification is the OQLF's recognition that an enterprise has completed francisation. A certified enterprise can display the certification mark and, in some cases, benefits from a lighter ongoing reporting burden. A particular agreement is a negotiated arrangement with the OQLF for enterprises whose situation does not fit the standard process.

In a plan, certification is evidence. If you hold it, say when you obtained it and what it covers. If you are working toward it, give the steps and the expected date, and do not overstate progress. Investors who operate in Quebec will check.

The OQLF publishes a list of enterprises that have not complied with the francisation process. Being named on that list carries commercial consequences: contract eligibility, public tenders and customer trust can all be affected. The list is public, and a plan that ignores it looks naive.

The enforcement evidence is published here: Administration publique- Liste des entreprises non conformes au processus de francisation.

Satisfying investors and language regulators in the same document

The two audiences want different things from the same pages, and the plan has to serve both without splitting into two stories. Investors want growth, margin and defensibility. The OQLF wants evidence that French is the normal language of your operations.

The bridge is operational detail. A language action plan with owners, dates and budget answers the regulator and reassures the investor that you understand your market. Vague commitments do neither.

Put the compliance summary near the front, not at the back. A Quebec lender or investor will look for it early, the same way a lender looks for risk before the numbers. The reasoning in business plan risk section applies directly: state the exposure, then state the control.

For market sizing, define your Quebec segments by behaviour and language preference rather than by broad demographic buckets. A francophone retail buyer and an anglophone online buyer may need different channels and different documents. The method in market analysis keeps the estimate built from a countable unit.

Give the cost line real numbers. Typical planning ranges, not quotes: certified French translation in Quebec runs about CAD 0.18 to CAD 0.30 a word, so an 8,000-word plan costs roughly CAD 1,500 to CAD 2,400 to translate.

A sector-aware review of the French pages typically adds CAD 1,000 to CAD 3,000. Committee time for a firm of 100 employees commonly totals 20 to 40 hours a year at loaded staff cost.

Finally, keep the plan honest about cost. Translation, review, committee time and staff training are real expenses in Quebec. A plan that shows them is more credible than one that claims language compliance is free. Regulators and investors both read the same number, and both will remember which plan respected their time.

Common questions