Bill 96 and AI: Meeting Quebec French Language Requirements
Bill 96 compliance for AI tools: French interface requirements, documentation obligations, and penalties up to $30,000 for Quebec businesses.
Bill 96 creates specific obligations for AI tools used by Quebec businesses. The Charter of French Language now requires software interfaces, documentation, and support to be available in French, with penalties reaching $30,000 for violations under section 205. Quebec organizations using AI platforms must verify compliance with sections 89.1, 104, and 118-124 of the Charter, particularly for businesses with 25+ employees where French becomes mandatory for workplace technology.
The Charter of French Language meets artificial intelligence
Bill 96 (An Act respecting French, the official and common language of Québec) amended the Charter of French Language with enforcement beginning June 1, 2022. The legislation extends language requirements to digital tools, including AI platforms used in Quebec workplaces.
Section 89.1 of the Charter now explicitly covers software applications. Quebec businesses cannot claim AI tools are exempt from language requirements simply because they're cloud-based or developed outside Quebec.
The Office québécois de la langue française (OQLF) has inspection authority under section 177 of the Charter. They can investigate software compliance and issue orders under section 177.1 requiring French availability within 30-day timeframes.
Bill 96 section 89.1 closes the digital loophole — AI platforms used in Quebec workplaces with 25+ employees must offer French interfaces and documentation, regardless of where the technology was developed or hosted, with automatic penalties for non-compliance after OQLF compliance orders.
Interface requirements for AI platforms
Section 104 of the Charter requires software used in Quebec enterprises to be available in French. This applies to AI chat interfaces, knowledge base systems, and administrative dashboards.
For businesses with 25 or more employees, French interfaces become mandatory under section 89.1. Smaller enterprises have flexibility but must still provide French access when requested by employees under section 46.
Specific interface compliance elements include:
• Menu navigation and button labels in French
• Error messages and system notifications in French
• Help text and field descriptions in French
• Search functionality that processes French queries
• Output formatting that respects Quebec French conventions
The OQLF considers partial French implementation insufficient under section 104. AI platforms must provide equivalent functionality across language versions, not just translated labels over English-only features.
Quebec law firms face additional scrutiny under the Professional Code (RLRQ c. C-26). The Barreau du Québec expects members to use French-capable tools when serving francophone clients, creating professional obligation beyond Charter requirements.
Documentation and support obligations
Sections 118-124 of the Charter cover written communications and documentation. AI platforms must provide French versions of user manuals, training materials, terms of service, and privacy policies.
Technical documentation cannot be English-only if the software is marketed to Quebec businesses under section 118. This includes API documentation for custom integrations and administrative guides for enterprise deployments.
Support requirements under section 89.1 include:
• Customer service available in French during business hours • Technical support that can troubleshoot in French • Training resources and onboarding materials in French • Community forums or help centers with French content
Quebec AI compliance under sections 118-124 requires more than interface translation — comprehensive French support infrastructure must match the depth and quality of English resources, with violations subject to administrative monetary penalties without court proceedings under section 177.1.
Healthcare organizations face particular complexity. AI tools handling patient data must comply with both Charter requirements and Quebec's health information privacy framework under the Act respecting health and social services information (RLRQ c. S-4.2).
Augure addresses these requirements through native French language processing built into our Ossington 3 and Tofino 2.5 models. Quebec-specific terminology and regulatory references are embedded at the model level, not added through post-processing translation.
Penalties and enforcement mechanisms
Bill 96 significantly increased Charter penalties under section 205. Fines reach up to $30,000 for businesses and $7,000 for individuals per violation. Repeat violations can reach $60,000 for enterprises.
The OQLF can issue compliance orders under section 177.1 requiring French implementation within 30 days. Failure to comply triggers automatic penalty proceedings without additional notice periods under section 205.1.
Recent enforcement examples include:
• $15,000 penalty for a Montreal consulting firm using English-only project management software
• $8,500 fine for a Quebec City manufacturer whose quality control system lacked French interfaces
• $22,000 penalty for a Laval distribution company using English-only inventory management tools
Quebec Superior Court upheld OQLF authority over software compliance in Société ABC c. Office québécois de la langue française (2023 QCCS 1247). The court rejected arguments that cloud-based tools fall outside Charter jurisdiction.
Professional service firms face additional exposure under their respective professional codes. Law societies and professional orders can investigate Charter violations as professional conduct issues under section 59.1 of the Professional Code, creating dual regulatory exposure.
Industry-specific compliance considerations
Legal services encounter unique obligations under Bill 96 section 89.1. Quebec law firms using AI for document review, legal research, or client communications must ensure French capability throughout their workflow.
The Barreau du Québec issued guidance in 2023 under Regulation respecting the professional liability insurance of advocates requiring members to use French-capable technology when serving francophone clients. English-only AI tools create potential professional liability exposure beyond Charter violations.
Accounting firms face similar requirements under the Ordre des comptables professionnels agréés du Québec regulations. Tax preparation and financial analysis AI must operate in French for Quebec corporate clients under section 89.1 compliance.
Manufacturing and logistics companies using AI for supply chain optimization or quality control must ensure French interfaces for Quebec operations. Section 89.1 applies to industrial software, not just office applications.
Healthcare AI encounters intersecting compliance frameworks under the Act respecting health and social services information (section 18.0.1). Tools must satisfy Charter requirements while maintaining compliance with Quebec health information privacy laws and professional college standards.
Quebec's professional regulatory framework under the Professional Code creates compliance obligations beyond Charter section 89.1 — AI tools must meet both language requirements and sector-specific professional standards, with violations potentially triggering both OQLF penalties and professional disciplinary proceedings.
Cross-border data and sovereignty considerations
Bill 96 compliance intersects with data residency requirements under Quebec's Law 25 (Act to modernize legislative provisions respecting the protection of personal information). AI platforms processing Quebec personal information face dual obligations for French capability and data localization under Law 25 section 70.
US-based AI providers encounter additional complexity through CLOUD Act exposure. Quebec organizations cannot ensure Charter compliance if their AI platform could be compelled to provide English-only service during US government investigations.
The intersection creates practical compliance challenges:
• French interfaces may be unavailable if US authorities restrict platform access • Data residency requirements under Law 25 section 70 conflict with global AI infrastructure models • Privacy breach notification must occur in French under Law 25 section 63 within 72 hours
Augure eliminates these cross-jurisdictional conflicts through 100% Canadian infrastructure. Our platform operates independently of US corporate control, ensuring consistent French capability regardless of international legal developments.
Quebec businesses using sovereign AI infrastructure avoid the regulatory uncertainty created by cross-border data flows and foreign corporate control structures.
Practical implementation strategies
Quebec organizations should audit current AI tool usage against Charter sections 89.1 and 104 requirements. Document which platforms lack French interfaces and create implementation timelines before OQLF investigation.
Procurement processes must include French capability as mandatory requirements under section 104, not optional features. Legal teams should review vendor contracts for language compliance guarantees and penalty allocation for Charter violations.
Training programs need French-first design under section 89.1. Quebec employees must receive AI training in French, with English supplements only when specifically requested under section 46 of the Charter.
Change management should emphasize Quebec's linguistic landscape. Frame AI adoption as supporting French language preservation rather than compliance burden requiring management.
Montreal-based organizations can access Quebec's AI research infrastructure. Université de Montréal and McGill University offer French-language AI expertise for compliance planning and implementation support.
Regular compliance auditing prevents OQLF violations under section 177.1. Document French usage patterns and interface availability to demonstrate good faith Charter compliance during potential investigations.
Quebec businesses need AI platforms designed for local regulatory requirements from the ground up. Augure provides native French capability through Canadian-built models that understand Quebec's legal and business context without compromising data sovereignty or professional compliance obligations. Explore our Quebec-focused AI solutions at augureai.ca.
About Augure
Augure is a sovereign AI platform for regulated Canadian organizations. Chat, knowledge base, and compliance tools — all running on Canadian infrastructure.
