Quebec Bill 96 and Bill 109: What Construction SaaS Companies Need to Know

A superintendent in Laval logs into the company’s time-tracking app on a Monday morning and finds every screen in English. Nothing about that used to raise an eyebrow. Today, it can trigger an OQLF complaint, a costly software retrofit, or worse, a fine the company never saw coming. Quebec's language rules have moved from job trailer paperwork straight into the software stack, and most construction firms haven't caught up.

Bill 96 finished its final rollout on June 1, 2025, and its workplace-language obligations affect the payroll platforms, time-tracking apps, and project management tools Quebec construction companies use every day.

A second law, Bill 109, passed in December 2025, takes a different angle and focuses on French-language discoverability on streaming and audiovisual platforms. The two bills are often mentioned together, but they don't apply to construction software the same way, so it is worth being precise about which one governs your day-to-day tools.

This article explains what each bill actually requires, who it affects, and what changes construction business owners, payroll administrators, and operations managers need to make now.

Key Takeaways

• Quebec’s French-language regime has long required French availability for workplace tools, including software, and Bill 96’s 2025 changes expanded the pool of employers subject to formal francization requirements.
• As of June 1, 2025, the francization registration threshold with the OQLF dropped from 50 employees to 25, pulling many mid-size contractors into the process for the first time.
• Businesses that reach the 25-employee threshold have six months from the end of the qualifying period to register with the OQLF, then three months from receiving their registration certificate to submit a linguistic self-evaluation.
• Adhesion contracts, including many SaaS subscription agreements, generally must be provided in French, though a party can choose to be bound by another-language version after receiving the French one.
• Fines for legal entities range from $3,000 to $30,000 for a first offence, $6,000 to $60,000 for a second, and $9,000 to $90,000 for subsequent offences, with each day of a continuing violation potentially counted separately.
• Bill 109 is a separate law aimed at streaming, audiovisual, and connected-device platforms. It does not currently regulate general construction management software, though its scope depends on regulations not yet published.
• Construction firms operating across provinces need a plan for Quebec-specific software configuration, not a single national default. They should confirm compliance directly with each vendor rather than assume it.

What Bill 96 Actually Requires From Construction Technology

Bill 96, formally the Act respecting French, the official and common language of Québec, amends the Charter of the French Language (Bill 101) and received assent on June 1, 2022. Its provisions rolled out gradually, with several of the strictest rules, including a lower francization threshold and tighter signage and trademark rules, taking effect on June 1, 2025.

French in the Digital Workplace

The requirement that workplace tools be available in French is not brand new. The Charter of the French Language has long required French versions of computer software, subject to certain conditions, and the broader workplace-language rules cover internal communications, training materials, work tools, and IT systems, with employees entitled to carry out their work in French.

What changed with Bill 96’s 2025 provisions is who is formally captured by the francization process built around those obligations, since the OQLF has flagged work tools such as software specifically when preparing newly captured employers for the June 2025 changes.

For a construction company, that language covers the tools crews and office staff touch daily: time clocks, job costing dashboards, HR portals, and payroll systems. If a foreman's tablet app only renders menus in English, that is a gap worth checking, even if it does not automatically mean the company is offside the law.

The 2025 Francization Threshold Change

Since June 1, 2025, any business that has employed 25 or more people in Quebec for six months is subject to the francization registration requirements, down from the old threshold of 50. Registration with the OQLF is due within six months of the end of that qualifying period. Once registered, the company receives a certificate of registration.

Then it has three months to submit a self-evaluation of its linguistic situation, which the OQLF uses to decide whether to issue a francization certificate or require a formal francization program. Many mid-size general contractors and specialty trade firms that never had to think about francization now fall inside this process, and the clock keeps running for any company that newly crosses the threshold.

SaaS Contracts and Adhesion Agreements

Most construction SaaS platforms are sold on standard-form terms that the client cannot negotiate line by line. Under the Charter, contracts of adhesion and related documents generally must be drawn up in French. A party can still be bound by a version in another language, but only after receiving the French version and expressly choosing the other-language version. That rule has applied since June 1, 2023, and it is relevant to the subscription agreements construction companies sign when they onboard new software.

Fines and Enforcement

Bill 96 raised the range of fines for legal persons from 1,500 to 20,000 dollars up to 3,000 to 30,000 dollars for a first offence. Fines double for a second offence and triple for any subsequent offence, and if a violation continues for more than one day, each day can count as a separate offence. The OQLF can investigate potential violations, respond to complaints, and take enforcement measures where it identifies non-compliance, and can also request an injunction to force compliance.

Before and After: How Bill 96 Changed Compliance for Construction Firms

What Bill 109 Does, and Why It Is Different From Bill 96

Bill 109 is worth understanding on its own terms, because it is not a construction-specific law and it does not regulate enterprise software the way Bill 96 does.

Scope: Streaming and Audiovisual Content, Not Back-Office Software

On December 12, 2025, the National Assembly of Quebec passed Bill 109, An Act to affirm the cultural sovereignty of Québec and to enact the Act respecting the discoverability of French-language cultural content in the digital environment, which aims to promote discoverability of and access to original French-language cultural content in the digital environment.

The Act establishes obligations for digital platforms offering online audiovisual, music, or audio content, as well as manufacturers of smart TVs and connected devices. Earlier drafting of the bill also referenced social media platforms and manufacturers of gaming consoles and media players, though exactly which services fall within scope, and under what criteria, depends on regulations the government has not yet published.

That definition targets services like video and audio streaming, not the payroll, time-tracking, and job-costing systems construction firms rely on.

A construction management platform is not a streaming service, and as currently written, Bill 109 does not impose discoverability quotas or French-default interface rules on that category of software.

Why Construction Tech Companies Should Still Pay Attention

Key details of the Act, including registration criteria for digital platforms, will be set out in forthcoming regulations, and the government plans to create a Bureau de la découvrabilité des contenus culturels within the Ministry of Culture and Communications to oversee compliance. Construction SaaS vendors that host training video libraries, onboarding media, or in-app content hubs should watch how those regulations define "digital platform." Until the regulations are published, it is not accurate to say Bill 109 directly governs typical construction management software.

An Uncertain Timeline

The legislation will come into force on a yet-to-be-determined date and is likely to face legal scrutiny. A jurisdictional question also remains, since broadcasting has traditionally fallen under federal authority through the Broadcasting Act, as amended by the Online Streaming Act.

Contractors should treat Bill 109 as a watch item, not an immediate action item, unless their software falls clearly within its audiovisual and streaming scope.

Practical Steps for Construction Companies Using SaaS Tools in Quebec

1. Track whether your business has employed 25 or more people in Quebec for the required six-month period, and confirm your applicable OQLF registration deadline.
2. Ask every software vendor, including payroll, time tracking, HR, and project management providers, whether their interface offers a complete French version, not just translated menus.
3. Review software agreements that qualify as adhesion contracts to confirm a French version was made available before any other-language version was signed.
4. Audit internal training materials, onboarding documents, and safety content delivered through apps or portals for French availability.
5. If you cross the 25-employee threshold, register with the OQLF within six months of the qualifying period ending, and prepare for the linguistic self-evaluation due within three months of receiving your registration certificate.
6. Keep a record of vendor compliance commitments in case of an OQLF complaint or audit.
7. Monitor Bill 109 regulations if your software includes video training libraries or media content features.

Common Mistakes Construction Firms Make

• Assuming that a French-language option in the software settings automatically satisfies workplace-language obligations, without checking whether the full functionality and required documentation are actually available in French.
• Missing the drop in the francization threshold and continuing to rely on the old 50-employee rule.
• Signing software contracts without confirming whether they qualify as adhesion contracts and, if so, whether a French version was made available first.
• Treating Quebec compliance as a marketing or signage issue rather than a payroll and workforce software issue.
• Waiting for a complaint or audit before reviewing vendor contracts and internal tools.

Frequently Asked Questions

Does Bill 96 apply to construction payroll and time tracking software?
Yes. Bill 96 requires that internal communications, training, work tools, and IT systems used by employees in Quebec be available in French. This includes payroll platforms, time-tracking apps, and job costing dashboards used by office staff and field crews. Contractors should confirm with each software vendor that the French version covers the full functionality employees rely on, not a partial translation of a few screens.

What is the francization threshold and did it change?
Francization is the process of registering with the OQLF and demonstrating that French is used as the normal language of work within a company. The threshold dropped from 50 employees to 25 as of June 1, 2025. A business that has employed 25 or more people in Quebec for six months must register with the OQLF within six months of that period ending, then submit a linguistic self-evaluation within three months of receiving its registration certificate.

Does Bill 109 require construction SaaS platforms to offer French content quotas?
Not directly. Bill 109 targets digital platforms offering streaming audio and audiovisual content, along with smart TV and connected device manufacturers. A construction management or payroll platform is generally outside that scope. The exception would be a platform with embedded video or media content libraries, where future regulations could affect classification.

What fines can a construction company face for Bill 96 non-compliance?
For a legal entity, fines range from $3,000 to $30,000 for a first offence, $6,000 to $60,000 for a second offence, and $9,000 to $90,000 for subsequent offences. If a violation continues for more than one day, each day may count as a separate offence. The OQLF can investigate potential violations, respond to complaints, and take enforcement action where it finds non-compliance.

Is Bill 109 already in force?
Bill 109 received assent on December 12, 2025, but it comes into force on a date the government will set, and key obligations depend on regulations that have not yet been published. Construction firms should treat it as an emerging area rather than an immediate compliance deadline.

Do multi-provincial construction companies need a separate Quebec configuration for their software?
In most cases, yes. A national default in English will not satisfy Bill 96 for Quebec-based staff. Companies operating in multiple provinces typically need vendor confirmation that the platform can be configured with a full French interface, French-first contracts, and French training materials for the Quebec workforce.

Final Thoughts

Bill 96 has already reshaped what construction companies need from their software vendors in Quebec, from the language of the payroll app on a foreman's phone to the contract signed when a new HR platform is onboarded. The lower francization threshold pulled many mid-size contractors into scope for the first time, and enforcement has become more active. Bill 109 is a separate and still-developing law focused on streaming and audiovisual content, with limited direct application to construction management software today.

The practical next step for contractors is straightforward: confirm in writing with every software vendor that Quebec-facing tools meet current French-language requirements, and revisit that confirmation as Bill 109 regulations take shape.

Lumber works with contractors across multiple provinces, including Quebec, and can walk through how a platform’s language settings and documentation align with your current compliance obligations.