Quebec's French-language commissioner has found that the province's health insurance agency is among seven major government bodies still operating bilingual websites in breach of the province's language law — a finding with direct implications for private insurers, brokers and managing general agencies operating in the province.
Two reports published May 27 by the commissioner's office conclude that the government is failing to achieve the objectives of Bill 96, the sweeping French-language legislation adopted three years ago.
The Régie de l'assurance maladie du Québec (RAMQ), which administers Quebec's public health insurance plan and prescription drug coverage for millions of residents, was among the agencies reviewed. Like the others, its website was found to remain generally available in both French and English, typically through a simple toggle that allows users to switch languages without verifying they qualify for a legal exception.
"Under these circumstances, it is difficult for users to understand that French is the official language of the province of Quebec and that French is the common language," one report states. Éric Poirier, deputy commissioner, was blunter: "It's as though the Charter of the French Language is not having the effects it should have. There are no observable structural effects."
Since June 1, 2023, contracts of adhesion, or standard-form contracts including insurance policies, phone plans and franchise agreements, must follow a two-step process. First, the business must present the French version to the other party, and only after the customer has examined it can both parties agree to use a version in another language. If no French version is offered first, the customer can demand that the contract be voided or that a non-compliant clause be struck.
An insurance contract in Quebec is generally considered a contract of adhesion, since its essential stipulations are drafted unilaterally by the insurer. This means that the French-first rule applies to the vast majority of policies written in the province. The government has clarified that documents related to a contract of adhesion include certificates of insurance, documents whose attachment is required by law, and related correspondence, extending the compliance obligation well into routine insurance operations.
Furthermore, the AMF has confirmed it does not intend to issue specific regulatory guidance on Bill 96, leaving each insurer, brokerage and MGA to interpret the legislation and determine its own compliance approach. Industry auditors advise that insurance providers should have a company-wide policy ensuring all staff understand their obligations, including the requirement to serve Quebec clients in French first.
The commissioner's findings arrive as Quebec's insurance sector is already managing a notably active regulatory agenda.
Bill 92, assented to in June 2025, made several changes to Quebec's insurance regulatory framework, including easing rules for claims adjusters, reducing disclosure requirements for damage insurance brokers, granting the AMF new governance powers, and increasing administrative monetary penalties to up to $2 million per day.
Bill 92 also merged the Chamber of Financial Security and the Chamber of Damage Insurance into a single new Chambre de l'assurance as of July 4, 2025, consolidating professional oversight across the sector.
The combination of Bill 96's language obligations, Bill 92's governance and penalty changes, and the AMF's June 2025 draft guidelines on the use of artificial intelligence by insurers means Quebec firms are simultaneously carrying a heavier compliance burden than at any point in recent memory.
The commissioner's reports also raised a concern that maps directly onto private sector operations.
Five of the seven agencies reviewed had no mechanism to ensure clients returned to French-only services after the six-month window in which new immigrants may be served in another language. Some acknowledged their computer systems could not track which legal exception applied to which client, with system modifications described as prohibitively costly.
The same gap exists in the client management systems of many private insurers. Where onboarding processes have recorded a client's preferred language without any mechanism to enforce a return to French-only service, insurers face both a compliance gap and a potential claims exposure if policy documents are later challenged on language grounds. Fines for non-compliance range from $3,000 to $30,000 per violation, with subsequent offenses subject to doubled or tripled penalties.
The commissioner's office has no enforcement powers but has announced it will follow up with the government in 2026. Its recommendations include requiring agencies to clearly identify the legal justification whenever services are offered in English, implementing automatic mechanisms to transition immigrants back to French-only service after six months, and requiring websites to publish information exclusively in French unless a specific legal exception applies.
