Bill 96 and websites: French language requirements in Quebec
Partner · Web development, SEO and GEO
Section 52 of the Charter of the French Language covers commercial documents regardless of the medium. Your website is one of them. The real test is not whether a French version exists, but whether it is available under conditions at least as favourable as the other version.
- Section 52 requires that catalogues, brochures, leaflets, commercial directories and order forms available to the public be drawn up in French, regardless of the medium.
- Section 52 also requires that the French version be available on terms at least as favourable. The application regulation permits two separate versions, one in French and the other in another language, provided accessibility and quality are no less favourable.
- That access test is what decides, and it is where most bilingual sites fail: incomplete journeys, a French form followed by an English email, deep pages never translated.
- The cost of a retrofit after the fact far exceeds that of a bilingual build from day one. On 400 pages, the gap runs to tens of thousands of dollars.
- This article describes the framework. It does not replace legal advice, and responsibility for compliance rests with the business.
On this page
What conditions at least as favourable means
The expression comes from the second paragraph of section 52 of the Charter of the French Language: no person may make a commercial document available to the public in a language other than French if the French version is not available on terms that are at least as favourable. Section 10 of the Regulation respecting the language of commerce and business permits two separate versions on a similar condition: no less favourable conditions of accessibility and quality. Applied to a website, the test is not about whether a translation exists, but about the ease of access, the completeness and the quality of what is offered in French.
What section 52 actually says
This article is written for executives of businesses that offer goods or services in Quebec and whose site is not entirely in French, or whose French version is incomplete. It describes the framework; it replaces neither a reading of the statute nor legal advice.
Here is what section 52 of the Charter of the French Language provides. Regardless of the medium used, catalogues, brochures, folders, commercial directories, order forms and any other documents of the same nature that are available to the public must be drawn up in French.
Three phrases do all the work. "Regardless of the medium", a wording Bill 96 added in 2022, removes the argument that the provision only covers print. "Any other documents of the same nature" covers what the list does not name. And "available to the public" covers what anyone can consult, which is the very definition of a commercial website.
Two other provisions govern the customer relationship. Section 5 establishes that consumers of goods and services have a right to be informed and served in French. Section 50.2 requires a business that offers goods or services to inform and serve consumers, and the public, in French.
The obligation therefore does not stop at the home page: it covers the entire relationship, from the first visit through to after-sales service.
The test that actually decides
Many businesses believe they are compliant because a French version exists. That is not the test.
Section 52 of the Charter adds, in its second paragraph, that no person may make such a document available to the public in a language other than French if the French version is not available on terms that are at least as favourable. Section 10 of the Regulation respecting the language of commerce and business permits two separate versions (one exclusively in French, the other exclusively in another language) provided the French version is available under no less favourable conditions of accessibility and quality.
The test is therefore about access, not existence. A French version that exists but is harder to reach, less complete, less current or of lower quality does not meet the condition, even if every word has been translated.
A site with 400 pages in English and 180 in French fails the test, whatever the quality of those 180 pages. The completeness gap is in itself a less favourable condition. It is the most common situation and the most expensive to fix, because it is discovered after years of unbalanced production.
Where bilingual sites break in practice
Six break points come up from one site to the next.
The transactional journey. A form in French, a confirmation email in English. A cart in French, a payment gateway in English, the gateway being the third-party tool that processes the card payment. It is the most common break point, because these elements often come from third-party tools.
Deep pages. Product pages, spec sheets and long-form articles are translated last, which means never. The completeness gap widens with every publication.
Downloadable documents. Spec sheets, warranties, manuals. They are covered like everything else, and they are almost always missing from inventories.
Customer service. Chatbot, knowledge base, canned replies. The obligation to inform and serve in French does not stop at the site.
Newsletters and social media. A commercial communication remains a commercial communication, whatever the channel.
Language detection. A site that defaults visitors to English based on their browser places the French version under less favourable conditions, even though both versions exist.
None of these six breaks is visible from the home page. To find them, you have to complete the full journey, in French, through to the order confirmation.
What late compliance costs
This argument carries the decision, because it turns a regulatory question into a budget trade-off.
Retrofitting a 400-page catalogue after the fact takes, on average, about 45 minutes per page between translation, adapting attributes and units, revision and integration. At 45 minutes and $65 per hour, the bill reaches about $19,500, not counting the retrofit of downloadable documents and transactional emails, those automated confirmation, invoice and delivery messages.
Building bilingual from day one costs a fraction of this amount. The structure is planned, the templates come in pairs, and translation fits into the production rhythm rather than into a catch-up. Templates are those page models reused across the entire site.
Add a cost nobody budgets: the executive time spent responding to a complaint, and the commercial risk of public coverage. In a regional market, that second cost often exceeds the first.
Redo this arithmetic with your real page count and your rate. What matters is not the amount, it is that it sits next to the cost of a bilingual build before the decision gets made by default.
The architecture that holds
Four decisions, made before the mockup rather than after.
The scope. Inventory everything available to the public: pages, downloadable documents, transactional emails, newsletters, customer service replies. It is a one-day exercise that prevents bad surprises.
The URL architecture. Two parallel trees, with a page-to-page mapping, rather than a partial translation grafted onto a single structure. The technical side of bilingualism directly crosses that of a large catalogue's architecture, covered in our article on product data maturity.
Translation priority. Four layers, in this order: the full transactional journey, the pages that generate inquiries, the catalogue's attributes and units, then the long descriptions. Translating out of order costs more and leaves the most serious breaks open the longest.
Governance. One written rule: no page is published in one language without its counterpart. Without that rule, the completeness gap starts widening again the month after compliance.
What triggers a complaint
The mechanism is simple, and you need to know it to assess the risk correctly.
The Office québécois de la langue française handles complaints from the public. Anyone can file one, including an unhappy customer, a competitor or a passerby. A business does not need to be large to be targeted, and websites have already faced proceedings based on section 52.
The cost of a complaint is not just the potential fine. The Office first asks for a correction within an agreed timeframe; the order and the penal proceedings come next, with a fine of $3,000 to $30,000 for a business, doubled for a repeat offence. It is the executive time it consumes and the retrofit done urgently, therefore more expensive, with a budget that was planned nowhere. In practice, the risk is not proportional to your visibility, but to how easily a visitor notices the gap. A site whose French version is visibly poorer is a report waiting to be filed.
The OQLF also publishes documentation for businesses, including a practical guide on social media. It is the first source to consult, before any vendor's interpretation, including ours.
Five things to verify this week
Responsibility for compliance rests with the business, never with the vendor that built the site. These five checks take one day.
- How many pages does your site have in each language, and what is the gap?
- Have you completed the full purchase journey in French, through to the confirmation email?
- Are your downloadable documents and transactional emails inventoried?
- Does your site default to a language other than French based on the browser?
- Who, on your team, confirms that no page is published without its counterpart, and is that rule written down?
A solid answer gives two page counts and the name of a person responsible. An evasive answer says the site is bilingual. A vendor that delivers a site without having inventoried transactional emails and downloadable documents has not addressed the question; it has translated pages.
Doing this inventory and putting a number on the gap before a complaint does it for you is the kind of assessment a paid audit produces.
What you keep in house: the legal validation of your situation, the publication rule and the scope decision. What gets delegated: the full inventory, the page-to-page mapping, the translation priority order, the template retrofit and the check of the transactional journey. A business that writes down its publication rule never lets the gap reopen. A business that fixes things once without a rule finds itself in the same place three years later, with a bigger catalogue, the same cost per page and a higher bill. It is an expense that repeats because nobody settled the rule.
This point sits within the thresholds described in building for three readers.
Starting from a blank page and want this settled at the design stage? See our work in web design.
French is not the only legal requirement bearing on your site: the framework and the risks are covered in our article on web accessibility obligations in Quebec.
Frequently asked questions about website language obligations
Is a website in English only permitted?
Section 52 covers commercial documents available to the public, regardless of the medium, and requires that they be drawn up in French. A business that offers goods or services in Quebec must also inform and serve its customers in French. Websites have already faced proceedings on this basis. Have your specific situation validated by legal counsel rather than relying on a general interpretation: the cost of an error is borne by the business, not by its vendor.
Do absolutely all pages have to be translated?
The regulation permits two separate versions, provided the French one is available under no less favourable conditions of accessibility and quality, and section 52 of the Charter requires the French version to be available on terms at least as favourable. A large completeness gap between the two versions makes that condition hard to defend. In practice, aiming for full parity is simpler, less risky and often less expensive than arguing over what might be missing.
My site is hosted outside Quebec. Am I covered?
What matters is the commercial activity carried on with the Quebec public, not the location of the server. A business that offers goods or services in Quebec is covered by the Charter. It is a question to validate legally based on your exact structure, especially if you have no establishment in Quebec.
What about the manufacturer's technical documents, which arrive in English?
They are covered like everything else if they are available to the public. The least expensive strategy is to translate the attributes, units and standards first, which are reusable across the whole catalogue, rather than the long descriptions, which are expensive and return little. That order cuts the bill roughly in half and protects the project's margin.
Is a trademark in English a problem?
Trademarks are subject to specific rules, amended by the provisions that came into force on June 1, 2025 on product inscriptions and public signage. The topic is separate from that of commercial publications and it carries precise conditions. It is a case to have validated by legal counsel, not to settle with an article.
Where should we start if the gap is large?
With the full transactional journey, from the form through to the confirmation email. That is where the failure is most visible to a customer and easiest for a complainant to observe. Deep pages come next, in order of the customer inquiries they generate. Starting with volume rather than the journey leaves the most serious break open the longest.
- Gouvernement du Québec, LégisQuébec, Charter of the French language (CQLR, c. C-11), sections 5, 50.2, 52 (second paragraph), 165.15, 165.22, 205 and 207, official text, accessed October 2026. Source of the terms at least as favourable test.
- Gouvernement du Québec, LégisQuébec, Regulation respecting the language of commerce and business (CQLR, c. C-11, r. 9), section 10, official text, accessed October 2026. Source of the two separate versions rule.
- Publications du Québec, Act respecting French, the official and common language of Québec (2022, chapter 14) (PDF, in French), sections 44 and 218, accessed October 2026. Source of “regardless of the medium used”.
- Office québécois de la langue française, Médias sociaux, guide à l'intention des entreprises (2025) (PDF, in French), accessed October 2026.
- Office québécois de la langue française, Dépôt d'une plainte ou d'une dénonciation, Étapes du traitement des plaintes et des dénonciations and Informations à lire avant de porter plainte ou de formuler une dénonciation (in French), accessed October 2026.
- Gouvernement du Québec, Infraction à la Charte de la langue française : le site Web d'Annexair inc. (March 10, 2023), Office québécois de la langue française, Infraction à la Charte de la langue française : le site Web de Fournitures Hermes inc. (May 9, 2025) and Gouvernement du Québec, Infraction à la Charte de la langue française : le site Web de URBN Canada Retail inc. (Anthropologie) (April 24, 2026), in French, accessed October 2026.
- Gouvernement du Québec, Protection du français : entrée en vigueur de nouvelles obligations pour les entreprises (May 30, 2025) and Office québécois de la langue française, Marques de commerce sur les produits, in French, accessed October 2026.
- Falia working framework, arithmetic of the cost of a late language retrofit. The amounts are explicit worked examples, to be redone with your page count and your rate.
Geneviève puts the strategy for your engagement into action. She leads all our web development projects: Shopify, WordPress and the new ways of building a site with AI. She manages our team of developers and translates your business needs into technical language. She runs your organic search (SEO), your visibility in AI answers (GEO) and your site's conversion rate optimization (CRO). Her work is at the heart of three goals: Attract customers with SEO and AI, Improve your site's conversion, and Strengthen your visibility in AI answers. With Gabriel, she also builds the landing pages for your advertising campaigns. She writes mainly about SEO, AI visibility and web design.
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