The autumn of 2025 was a whirlwind for Québec’s labour market. The National Assembly, after years of lobbying by unions, employers, and health professionals, passed reforms to modernize antiquated systems. Based on official sources such as the National Assembly of Québec, the Commission des normes, de l’équité, de la santé et de la sécurité du travail (CNESST), SOQUIJ, and the Gazette officielle du Québec, this summary explores the main amendments. We’ll explore not just what happened, but why it matters, how it affects you, and what steps to take next. Strap in – this isn’t just legal jargon; it’s about building fairer, safer workplaces in a province that prides itself on being a leader in labour rights.
These changes follow earlier reforms such as the progressive implementation of the updated occupational health and safety regime. But fall 2025 sped things up, with steps to simplify disputes, increase union transparency, and tackle sexual violence directly. Let’s break it down, starting with the big players: Bill 101, Bill 3, and a pivotal draft regulation. You’ll walk away with a plan to navigate these changes, whether you’re an employer setting policies or an employee standing up for your rights.
Bill 101: The Amendment That’s Changing the Game for Daily Work
Bill 101, or “An Act to amend various labour laws,” isn’t just a bill; it’s a tune-up for Québec’s labour engine. Passed by the National Assembly in October 2025 and approved shortly thereafter, this bill covers everything from grievance procedures to health crises. It stems from long-standing grievances over arbitration delays, legal inconsistencies, and worker protection loopholes revealed by incidents like the COVID-19 pandemic.
Think of Bill 101 as a Swiss Army knife for labour issues. According to explanatory notes from the National Assembly (available at https://www.assemblee-nationale.qc.ca/en/actualites-et-evenements/fil-information/parlementaire/projet-loi-101-2025), the bill’s goals are straightforward yet ambitious: streamline disputes, clarify rules, amp up prevention, and hike penalties for violations. For employers, this means tighter deadlines and more paperwork upfront, but potentially fewer courtroom headaches down the line. For workers, it promises faster justice and better safeguards.
Grievance Made Easy: Arbitration in the Labour Code
A key battleground in the bill is its overhaul of grievance arbitration processes in the Labour Code. If you’ve ever been stuck in a long-running dispute – maybe over unfair dismissal or unpaid wages – you’ll know the frustration of constant delays. Bill 101 addresses this directly, bringing order to the chaos.
Effective for grievances filed on or after October 28, 2025, parties must exchange documentary evidence and witness lists 30 days prior to hearings. This is not optional, it’s to reduce surprises and adjournments. As SOQUIJ’s labour relations blog points out, this encourages preparation and respects arbitral resources.
But the game changer comes on October 28, 2026: Strict timelines for arbitrator designation (within six months of filing) and hearing starts (within one year). Missed the 6-month mark? The complaint is deemed abandoned, but it’s a rebuttable presumption, so you can appeal to the Administrative Labour Tribunal (TAT) if you have a valid reason, such as unexpected delays. This “use it or lose it” mentality keeps unions and employers on their toes, potentially clearing backlogs that have plagued the system for years.
Why does this matter? In a province where labour disputes can last months or years, these changes could save time and money. For example, a factory workers’ union might now focus on strong cases upfront, and employers can better estimate legal expenses. But critics fear smaller unions could be overwhelmed by the speed, resulting in inadvertent forfeitures. Employers should review their internal procedures now, maybe looking at L’Express Travail from SOQUIJ for case studies on similar changes.
These rules apply broadly to private and paraprivate sectors but exclude public ones, which have their own frameworks. It’s a targeted fix, but one with wide ripples.
New Leaves and Safeguards
Changing the subject, Bill 101 also strengthens the Act respecting labour standards, creating a new unpaid leave for public health or civil security reasons. Imagine: Wildfire evacuation or a new pandemic wave, and you’re stuck at home. Before, you’d use vacation or sick time; now, this leave allows you to take time off without being penalized.
Importantly, employers can’t require a medical certificate—a pandemic lesson learned when paperwork stood in the way. This measure, starting October 28, 2025, seeks to alleviate hardships in times of crisis, in line with wider occupational health objectives.
Other changes include definitions for “incorporated workers” (those working through corporations) to receive some protections, easier reimbursements for reassigned pregnant workers and strengthened CNESST powers, such as increased fines for violations in health, education and construction. These aren’t sexy, but they’re functional, like less room for worker misclassification or cutting corners on safety.
For employers, that means HR handbooks need to be updated ASAP. A restaurant chain, for instance, could update absence policies to incorporate this leave, educating managers on how to respond to requests with empathy. Employees get peace of mind, knowing emergencies won’t cost jobs.
Occupational Health and Safety: No Delays on Prevention
Bill 101 initially flirted with delaying parts of the modernized occupational health and safety regime, but amendments scrapped that idea. As a result, the Regulation respecting prevention mechanisms and participation in establishments roared into effect on October 1, 2025, as planned .
This regulation mandates health and safety committees, worker representatives, and prevention programs in establishments with 20+ workers. It’s a proactive shift: Instead of reacting to accidents, businesses must anticipate them. For a mid-sized office, this could mean appointing a safety rep and running regular risk assessments.
Bill 101 reinforces this by harmonizing definitions and obligations, ensuring consistency across statutes. The upshot? Safer workplaces, but with compliance costs—training, documentation, and potential fines if ignored. CNESST bulletins emphasize that these aren’t optional; they’re core to Québec’s vision of preventive health.
In sum, Bill 101 isn’t revolutionary, but it’s evolutionary, fine-tuning systems for a modern economy. Employers ignoring it risk penalties; those embracing it could foster better employee relations.
Bill 3: Transparency and Governance in the Spotlight
If Bill 101 is about efficiency, Bill 3 is about trust. Tabled on October 30, 2025, as “An Act to improve transparency, governance and the democratic process of various associations in the workplace,” this bill targets unions and worker associations .
As of January 2026, it’s still in committee, with consultations ongoing. But its potential impact is huge: It seeks to make unions more accountable, ensuring members have a real say in how their dues are spent. In an era of skepticism toward institutions, this bill addresses calls for reform from within the labour movement and beyond.
The Dues Divide: Mandatory vs. Voluntary – A Funding Firewall
At its heart, Bill 3 draws a line between “principal” and “optional” union dues. Principal dues cover essentials like bargaining, grievances, and admin— the bread-and-butter of representation. Optional ones fund extras: constitutional challenges, ads, or political demos not tied to labour rights.
The bill bans using principal dues for optional activities, forcing segregation. Why? To prevent misuse and ensure transparency. Members must approve principal dues via secret ballot majority, and optional ones annually. This annual renewal keeps consent fresh, empowering rank-and-file workers.
Imagine a construction union: Principal dues might pay for contract talks, while optional could back a campaign against unsafe regs. Members vote on both, ensuring buy-in.
Longer Periods for Broader Participation
Bill 3 mandates 24-hour minimum voting periods for key decisions- dues, strikes, agreement ratifications. This extends access, especially for shift workers or remote members. It’s a democratic booster, potentially increasing turnout and legitimacy.
Governance gets an upgrade too: Annual financial statements, resource use reports, and clear rules for votes and officers. Non-compliance? Fines for associations and leaders, adding teeth.
The government’s impact analysis predicts smoother operations but warns of admin burdens for smaller unions. Sectors like construction, with complex associations, could see the biggest shifts.
As consultations wrap (involving groups like the FTQ), amendments might soften edges. Employers should watch closely, stronger union governance could mean more stable bargaining, but also tougher negotiations if members feel empowered.
The Draft Regulation on Sexual Violence Prevention
On 29 October 2025, the Gazette officielle du Québec published the Draft Regulation respecting measures to prevent or put an end to a situation of sexual violence
https://www.publicationsduquebec.gouv.qc.ca/fileadmin/gazette/pdf_encrypte/gaz_entiere/2544-F.pdf
This draft regulation gives operational content to section 51(16) of the Act respecting occupational health and safety, which obliges employers to protect workers from physical and psychological violence, including sexual violence.
Employer Mandates: From Awareness to Action
The draft requires informing workers of workplace-specific risks and controls. Training is key: Mandatory sessions on prevention, with CNESST-prescribed content .
Complaint procedures must be established, with a designated competent person handling them. Confidentiality is paramount, protecting reporters from retaliation.
This applies universally, no size exemptions. For a retail store, it might mean risk-mapping (e.g., late shifts) and annual training. Unions and orgs had 45 days to comment; final adoption is slated for 2026, with transition time.
Why engaging? Because sexual violence isn’t abstract- it’s a barrier to equity. This reg shifts from reaction to prevention, fostering cultures where everyone feels safe.
Trends, Strategies, and Stakeholder Perspectives
These reforms converge on prevention, structure, and accountability. Procedural timelines in Bill 101 demand agility; Bill 3’s transparency could reshape union dynamics; the sexual violence reg emphasizes psychosocial health.
- For employers: Audit grievances, update policies, integrate training. Hypothetical: A tech firm might simulate timelines to avoid withdrawals, while weaving sexual violence modules into onboarding.
- Workers benefit from faster resolutions and stronger protections, but must engage in votes.
- Unions face scrutiny but gain credibility through democracy.
Challenges? Compliance costs for SMEs, potential overreach in dues rules.
Key Measures at a Glance
| Instrument/Source | Domain | Key Measures | Status/In-Force Date | Main Obligations for Employers |
|---|---|---|---|---|
| Bill 101 | Labour relations (Labour Code) | Disclosure of evidence/witnesses | Oct 28, 2025 | Provide lists 30 days pre-hearing |
| Bill 101 | Labour relations (Labour Code) | Timelines for arbitrator/hearing | Oct 28, 2026 | Designate within 6 months; start within 1 year |
| Bill 101 | Labour standards | New unpaid leave for health/security | Oct 28, 2025 | Grant leave; no medical cert required |
| Bill 101 | OHS/Labour standards | Technical amendments (workers, fines) | Oct 28, 2025 | Adjust classifications, apply new standards |
| Prevention Regulation | OHS | Committees, programs | Oct 1, 2025 | Establish structures for 20+ workers |
| Bill 3 | Union governance | Dues distinction, voting | Tabled Oct 30, 2025; under study | Prepare for dues approvals, reporting |
| Sexual Violence Draft Reg | OHS/Psychosocial | Info, training, complaints | Draft Oct 29, 2025; 2026 adoption | Identify risks, train, designate handler |
Looking Ahead: Staying Ahead of the Curve
As 2026 unfolds, monitor Bill 3’s passage and the reg’s finalization. Québec’s labour laws are evolving toward equity and efficiency, embrace them for resilient workplaces. For tailored advice, consult experts; resources like CNESST and SOQUIJ are invaluable.
Frequently Asked Questions: Demystifying Québec’s Labour Law Shake-Up
- When did Bill 101 come into force, and what are the main changes for grievance arbitration? Bill 101 (Loi visant l’amélioration de certaines lois du travail) was adopted and sanctioned in October 2025 (royal assent October 28, 2025). Disclosure of evidence and witness lists (at least 30 days before hearing) applies to grievances filed on or after October 28, 2025. Stricter timelines start October 28, 2026: arbitrator designation within 6 months (presumed withdrawal if missed, but rebuttable via TAT), and hearing normally within 1 year. This aims to reduce long delays in private/parapublic sectors.
- What is the new unpaid leave in Bill 101, and can my employer ask for a medical certificate? Bill 101 adds an unpaid, protected leave for absences due to public health orders or civil security emergencies (e.g., evacuation, pandemic measures). In force since October 28, 2025. Employers cannot require a medical certificate for this leave, easing access during crises.
- Did Bill 101 delay occupational health and safety (OHS) prevention mechanisms? No final delay for most employers. Early drafts proposed postponing some prevention programs/committees (from Bill 59 modernization), but the adopted version kept the October 1, 2025 entry into force for the Regulation respecting prevention mechanisms and participation. Workplaces with 20+ employees need committees, programs, and reps; smaller ones need action plans. Some sector-specific adjustments (e.g., health/education) exist, but the core rollout happened as planned.
- What does Bill 3 propose for union dues and transparency? Tabled October 30, 2025 and still under study/consultations (as of January 2026; not yet law). It splits dues into “principal” (core representation like bargaining/grievances) and “optional” (e.g., political activities, ads, certain lawsuits). Principal dues need majority secret ballot approval; optional require annual renewal vote. Key votes (dues, strikes, agreements) must last at least 24 hours. Unions would need annual financial reports and face fines for non-compliance. Unions criticize it as interference; government calls it member protection.
- When will Bill 3 become law, and why are unions opposing it? Not in force yet—still in parliamentary process with consultations ongoing into 2026. Unions argue it “muzzles” them by restricting how dues fund non-core activities (e.g., constitutional challenges or demos), adds bureaucracy, and weakens solidarity. Protests occurred in late 2025. Employers should monitor as it could affect bargaining dynamics if passed.
- What does the draft regulation on sexual violence (October 2025) require from employers? Published in Gazette officielle October 29, 2025 (not yet in force; final expected 2026 after comments). Employers must: inform workers of workplace-specific sexual violence risks; provide prevention training (every 3 years, per CNESST content); establish a complaint/reporting procedure; designate a competent, impartial person to handle cases; ensure confidentiality and no reprisals. Applies to all employers, no size exemption. Builds on 2024 laws making sexual violence a recognized psychosocial hazard.
- When will the sexual violence prevention regulation take effect, and what should employers do now? Not yet law—consultation period ended December 2025; adoption and transitional implementation likely in 2026. Prepare by updating harassment/violence policies, mapping risks (e.g., lone shifts, client interactions), planning training, and naming a handler. Integrate with existing OHS psychosocial requirements (in force since October 2025).
- Do I need a health and safety committee or representative under the 2025 OHS changes? Yes, since October 1, 2025 (Regulation under modernized regime). Workplaces with 20+ workers need a joint committee, prevention program, and worker rep(s). Under 20: designate a liaison and implement an action plan. Psychosocial risks (stress, harassment, violence) must be addressed. Non-compliance risks higher fines.
- How do these changes affect small businesses in Québec? Most apply universally (e.g., sexual violence info/training, no medical cert for new leave, OHS action plans for small sites). Grievance rules mainly hit unionized/parapublic sectors. Bill 3 (if passed) impacts unions more than direct employers. Small firms should focus on low-cost steps: update policies, track grievances tightly, and use CNESST guides for compliance.
