Fast-Track · Weeks, Not Months

Quebec Law 25 Compliance

Quebec Law 25 (Bill 64) Privacy Compliance for Organizations Handling Quebec Data

Praxis-Q delivers Quebec Law 25 compliance for organizations that collect or process the personal information of Quebec residents - privacy governance, consent management, PIA/DPIA, breach response and cross-border transfer controls aligned to the CAI requirements.

At a Glance

Law

Law 25 / Bill 64

Penalty

to $25M / 4%

Regulator

CAI

Market

Quebec, CA

Law 25 (formerly Bill 64) rolled out to organisations processing Quebec residents' personal information in three phases between September 2022 and September 2024, and by now every obligation - privacy officer designation, Privacy Impact Assessments for cross-border and third-party transfers, breach notification to the Commission d'accès à l'information, the right to de-indexing and the right to portability - is fully in force. Two separate penalty tracks apply: administrative monetary penalties of up to CAD 10 million dollars or 2% of worldwide turnover for regulatory contraventions, and penal fines of up to CAD 25 million dollars or 4% of worldwide turnover for the more serious offences, both enforced by the CAI, which has been notably more active than most Canadian provincial regulators since the law came fully into force. Praxis-Q builds Law 25 governance - privacy officer role, consent mechanisms, PIA methodology, breach procedures - mapped to whichever phase obligations the organisation may still be catching up on, and aligned with any GDPR programme already in place given the two laws' structural similarity.

Quebec Law 25

Quebec Law 25 Compliance

Quebec Law 25 (Bill 64) Privacy Compliance for Organizations Handling Quebec Data

The Problem

Quebec Law 25 is the strictest privacy law in Canada, with penalties up to $25M or 4% of worldwide turnover. Most organizations still lack the privacy officer, consent records and breach procedures it now requires.

What We Do

  • Gap Assessment
  • Governance
  • Consent & Rights
  • PIA & Transfers
  • Breach Readiness

What You Get

  • Gap assessment against all Law 25 obligations
  • Privacy officer role and governance setup
  • Consent and transparency mechanisms
  • Privacy Impact Assessments (PIA/DPIA)
  • Breach notification process to the CAI
  • Cross-border transfer impact assessments
  • Data retention and de-indexing rights
  • Records of processing and policies

Why weeks, not months

AI-assisted evidence review, one client portal

Every Quebec Law 25 engagement runs on the Praxis-Q compliance platform. You upload evidence per control, AI scores it against the requirement, and your auditor reviews in the same workflow — from scoping through to the issued, publicly verifiable certificate.

AI evidence scoring

Every upload is scored against the control before an auditor sees it — gaps surface in minutes, not at the review meeting.

One client portal

Scoping, evidence, auditor queries and status live in one place. No email chains, no spreadsheet trackers.

Auditor sign-off

Praxis-Q auditors review inside the same workflow, so review rounds shrink and the certificate issues sooner.

Law 25's Three-Phase Rollout and Where Obligations Stand Now

Law 25 came into force in three tranches: September 2022 brought the mandatory privacy officer designation (by default the CEO, unless the role is delegated) and breach notification duties; September 2023 added consent requirements, privacy-by-default settings, and the rights to portability and de-indexing; September 2024 completed the rollout with the biometric information registration requirement and the remaining data portability provisions. Organisations that built their programme around only the September 2022 requirements are commonly missing two full years of subsequent obligations. Praxis-Q's gap assessment checks against all three phases explicitly rather than assuming an early compliance effort is still current.

Two Penalty Tracks: Administrative Monetary Penalties and Penal Offences

Law 25 created two distinct enforcement mechanisms that are often conflated. Administrative monetary penalties, issued directly by the CAI without a court process, run up to CAD 10 million dollars or 2% of worldwide turnover for the prior fiscal year, whichever is greater, for contraventions like inadequate consent mechanisms or missing PIAs. Penal offences - the more serious track, requiring prosecution - carry fines up to CAD 25 million dollars or 4% of worldwide turnover, reserved for matters like knowingly communicating personal information without consent or obstructing a CAI investigation. Praxis-Q's risk assessment flags which gaps expose an organisation to which track, since the response and remediation priority differ.

Privacy Impact Assessments for Transfers Outside Quebec

Law 25 requires a documented PIA before any communication of personal information outside Quebec, assessing whether the destination provides protection 'equivalent' to Quebec's regime - a materially different and, in places, stricter standard than GDPR's adequacy-decision model. This catches routine SaaS and cloud vendor relationships that organisations often don't think of as a 'transfer' at all: a Quebec entity using a US-hosted CRM or an offshore support team touching customer records needs a PIA on file for that relationship specifically. Praxis-Q builds the PIA methodology and works through the existing vendor list to identify which relationships need one retroactively.

The Privacy Officer Role and Governance Structure

By default, the person exercising the highest authority in the organisation (usually the CEO) is the privacy officer under Law 25 unless that function is formally delegated in writing - and delegation is the practical norm for anything beyond a very small organisation. The role carries real operational duties: approving PIAs, handling data subject requests, managing breach response, and being CAI's point of contact. Praxis-Q sets up the delegation documentation, defines the operating procedures the privacy officer needs, and can provide privacy-officer-as-a-service for organisations that need the function covered without a dedicated internal hire.

Aligning Law 25 with an Existing GDPR or PIPEDA Programme

Law 25 was deliberately modelled on GDPR, so organisations with an existing GDPR programme are closer to compliant than they realise - consent standards, breach notification concepts, and privacy-by-design principles carry across structurally. The gaps are specific: Law 25's transfer PIA standard, its biometric information registration requirement, and its de-indexing and portability rights don't have exact GDPR equivalents and need their own procedures. Praxis-Q builds on an existing GDPR or federal PIPEDA programme rather than starting a parallel Quebec-only compliance effort, mapping the genuine gaps rather than re-documenting what's already in place.

Frequently Asked Questions

Who must comply with Quebec Law 25?
Any organization, inside or outside Quebec, that collects, holds or processes the personal information of Quebec residents, regardless of size.
What are the Law 25 penalties?
Administrative monetary penalties up to $10M or 2% of worldwide turnover, and penal fines up to $25M or 4% - among the highest in North America.
How does Law 25 differ from PIPEDA?
Law 25 is stricter: mandatory privacy officer, PIAs, explicit consent, breach reporting to the CAI, plus data portability and de-indexing rights beyond PIPEDA.
Are all of Law 25's requirements now in force?
Yes. The law rolled out in three phases from September 2022 (privacy officer, breach notification) through September 2023 (consent, privacy-by-default, portability and de-indexing rights) to September 2024 (biometric registration, remaining portability provisions). Every obligation is fully in force now; there's no remaining phased deadline to plan around, only the risk of a compliance programme built for an earlier phase that hasn't been updated.
What are the actual penalties under Law 25?
Two separate tracks. Administrative monetary penalties, issued directly by the CAI, run up to CAD 10 million dollars or 2% of worldwide turnover for regulatory contraventions. Penal offences - a more serious, court-prosecuted track - carry fines up to CAD 25 million dollars or 4% of worldwide turnover, reserved for the most serious violations such as knowing unauthorised disclosure. Most organisations' realistic exposure is the administrative track for gaps like missing consent mechanisms or PIAs.
Who has to be the privacy officer?
By default, whoever holds the highest authority in the organisation - typically the CEO - unless that function is formally delegated in writing to someone else. For any organisation beyond a very small size, delegation to a dedicated or part-time privacy officer is the practical approach, since the role carries genuine ongoing duties: PIA approval, data subject request handling, and being the CAI's point of contact.
Does moving data to a US cloud provider count as a transfer under Law 25?
Yes, and it requires a documented Privacy Impact Assessment before the transfer, assessing whether the destination offers protection equivalent to Quebec's regime. This applies to routine vendor relationships - a US-hosted CRM, an offshore support team with access to customer records - not only to obvious cross-border data sales. Many organisations only discover this requirement once a gap assessment reviews their actual vendor list.
How does Law 25 differ from GDPR if we already have a GDPR programme?
Structurally similar - Law 25 was modelled on GDPR - but not identical. The transfer PIA standard is its own test, not GDPR's adequacy-decision model; the biometric information registration requirement and the specific de-indexing right don't have direct GDPR equivalents. Praxis-Q builds on an existing GDPR programme and closes the Law 25-specific gaps rather than duplicating what already exists.
Does Law 25 apply if we're based outside Quebec?
Yes, if you collect or process the personal information of Quebec residents, regardless of where your organisation is based - the law applies based on whose data is processed, not where the processor is located. This catches many Canadian and US organisations with Quebec customers who assume a provincial privacy law only concerns Quebec-headquartered businesses.

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