Selling Ticket Seats Or Subscriptions In Québec? Bill 10 Changes The Conditions Of Entry

At first glance, ticketing systems and subscription platforms may not seem to have much in common. But in recent years, both of these have undergone rapid evolution with business practices often developing faster than regulatory frameworks can keep pace. With rising attention on resale pricing and the continued growth of auto-renewing digital services, Québec is looking to update its playbook, or rather, its laws.

On December 2, 2025, the Québec government introduced Bill 10, An Act to protect consumers against abusive practices in ticket reselling and online subscription renewal ("Bill 10"). This Bill proposes new rules aimed at balancing these evolving business models with clearer standards for resale practices and subscription renewals. For businesses operating in Québec, this is a signal that compliance obligations in both areas are entering a new chapter.

Below, we've summarized some of Bill 10's key legislative changes:

Ticket resale

If the last few years have proven anything, it's that major live events have made ticketing one of the hottest (and most lucrative) topics in the entertainment industry. From the Eras Tour to the World Series and everything in between, demand has routinely pushed platforms—and resale ecosystems—to their limits. And with the 2026 World Cup on the horizon, the pressure isn't likely to ease.

Against this backdrop, Bill 10 proposes new rules specifically aimed at how tickets can be resold in Québec. These include notably:

• Initial disclosure requirements: Anyone operating a digital ticket resale platform would be required, "as soon as the consumer access the platform," to inform the consumer "in a prominent and intelligible manner" (i.e. not buried in fine print or in the T&Cs) that they are on a resale platform and that less expensive tickets may be available from the official vendor.
• Pre-purchase disclosure requirements: Before reselling a ticket to a consumer, certain information would have to be "expressly brought to the attention of the consumer." This includes, among other things, the name of the prior owner of the ticket and the specific seat or location to which the ticket grants access.
  
  However, the Bill does not specify how this information must be presented or what steps would be sufficient to meet the "expressly brought to the attention of the consumer" standard. As a result, further guidance is welcome to determine how this obligation should be applied in practice.
• Event changes or cancellation: Bill 10 would introduce disclosure obligations at two distinct levels in the event of a cancellation, or a change to an event's schedule or location:
  • The event producer would be required to inform the authorized ticket seller and any reseller with whom the producer has entered into a ticket resale agreement of the change or cancellation.
  • Any person who sells or resells a ticket to a consumer would be required to inform the consumer of the change or cancellation.
    
    In both cases, the information must be disclosed "as soon as possible."
• Prohibition on transfer fees: If Bill 10 is adopted in its current form, charging a fee for the transfer of a ticket would be prohibited. However, a transfer fee does not appear to be the same as reselling a ticket above its face value (see further discussion below).
• Extension of requirements to third parties: Bill 10 provides that "[a]nyone who, by a technological means, allows a third person to resell a ticket and receive payment of the price of the ticket" will be deemed a reseller, and subject to the requirements applicable thereto. It remains unclear how broadly this will be interpreted in practice.
  
  For instance, if a consumer can purchase a ticket and make payment through one platform, but the ticket transfer must occur via a different platform, it is uncertain whether the payment platform would also be captured under this provision. This ambiguity could create compliance challenges for digital platforms that facilitate ticket transactions via third-parties.
• Resale at a higher price: The Bill's provision on resale of tickets at a price above the initial sale price has drawn significant attention since its release. However, this provision is not new. It essentially mirrors existing requirements under Québec's Consumer Protection Act ("CPA"), which provide that a ticket may only be resold at a higher price if:
  • The event producer has consented to the resale.
  • The resale complies with the reseller's agreement with the producer.
  • The consumer is informed, prior to purchase, of the maximum resale price agreed to by the producer.

Just as noteworthy as what Bill 10 seeks to regulate is what it pointedly does not address. In particular, the Bill is silent on dynamic pricing.

Dynamic pricing – sometimes referred to as surge pricing – is the practice by which a vendor adjusts ticket prices in real time in response to supply-and-demand conditions. In the event-ticketing world, dynamic pricing has drawn significant public and regulatory attention, especially as prices for high-demand events have, at times, risen dramatically within minutes of going on sale.

Regulators across the globe, including the Competition Bureau of Canada earlier this year, have examined dynamic pricing and related digital marketplace practices with increasing scrutiny. Considering the growing regulatory and consumer scrutiny of dynamic pricing, many would expect that any modernization of the ticket-sale rules would speak to this practice. At least in its current form, however, Bill 10 does not.

Additional changes to Québec's ticketing framework

Bill 10 does, however, propose other meaningful changes to Québec's ticketing framework. Notably, it introduces a new presumption of responsibility for intermediaries: any person or entity who, through technological means, enables a third party to resell a ticket and receive payment will be deemed subject to both the existing and the newly added ticket-sale obligations under the Consumer Protection Act.

This presumption is broad and appears designed to capture digital platforms and automated tools that facilitate resale activity even where the intermediary does not itself take possession of the ticket.

Contracts for sequential performance

Contracts for sequential performance – essentially, recurring subscription-type agreements – have not faced the same level of public scrutiny in recent years as soaring ticket prices. Yet they remain a consistent source of consumer frustration and regulatory interest.

Most consumers are familiar with the experience: signing up for a "free trial" with the best of intentions to cancel before the promotional period ends, or vowing to pare down the ever-growing list of streaming platforms quietly renewing each month. These everyday pain points underpin a broader policy concern about how subscriptions are marketed, renewed, and cancelled.

Bill 10 does not attempt a wholesale reform of the existing statutory framework governing contracts for sequential performance. Instead, it introduces a set of targeted amendments aimed at enhancing transparency and reducing unwelcome surprises for consumers. The emphasis is on ensuring that consumers understand what they are signing up for, how much it will cost, when and how it will renew, and how easily it can be cancelled.

In this spirit, Bill 10 proposes several notable updates to the rules applicable to subscription-based offerings, including:

• Easier and more accessible cancellation mechanisms: Where a merchant enters into an online contract for sequential performance that a consumer may cancel "without cause", Bill 10 would require the merchant to provide "a button accessible online and readily identifiable that allows the consumer to easily exercise that [cancellation] right."
  
  In practice, this means that merchants will no longer be able to rely on friction-heavy cancellation processes, such as requiring a consumer to send an email, call customer service, or navigate multiple screens or menus to terminate an online subscription. Instead, the legislation contemplates a simple, immediate, and user-friendly "cancel" button, positioned in a way that allows consumers to exercise their right of cancellation without obstacles or delays.
  
  This aligns with a broader regulatory trend in Canada and internationally, where lawmakers are increasingly targeting "dark patterns" and other digital design practices that impede consumer choice.
• Mandatory notice before a promotional period ends: Bill 10 also addresses promotional pricing structures, such as offers like "You first month free" or "$0.99 for the first week only," where a consumer benefits from free or discounted access for a limited period before being charged the standard rate.
  
  Under the proposed amendments, where a consumer enters into such a contract, the merchant will be required to send the consumer – between 2 and 10 days before the end of the promotional period – a clear, legible notice that specifies:

1. The exact date on which the promotional period will end.
2. The price that will apply thereafter.

• Disclosure of additional amounts payable for a service provided at a distance: Bill 10 will also require that where a merchant "announces the amount of the instalments to be paid to obtain a sequential performance service provided at a distance" the merchant will also have to indicate clearly and legibly, next to this amount, the amount of any "fees charged other than by instalments to obtain the service."
  
  This requirement works alongside existing obligations under the Québec Consumer Protection Act and the federal Competition Act, both of which mandate that advertised prices include all fees and charges imposed by the merchant.
  
  In our view, the "fees charged other than by instalments" referenced in Bill 10 would capture any mandatory additional amounts a consumer must pay to access the service—for example, equipment or activation fees. To illustrate: if a merchant advertises the monthly instalment price for home internet services, and a consumer must purchase a modem or router to access the service, the cost of that equipment would likely constitute a "fee charged other than by instalments" and would need to be disclosed alongside the advertised instalment amount.

Key takeaways

Bill 10 signals a meaningful shift toward greater transparency, consumer autonomy, and digital fairness in Québec's consumer marketplace, particularly for online commercial practices. The Bill prioritizes pre-transaction clarity, mandatory consumer notifications, and simple, user-friendly cancellation mechanisms, reflecting broader legislative trends aimed at curbing misleading design practices and reducing consumer "friction" in digital environments.

That said, Bill 10 is still at an early stage of the legislative process, and its provisions may evolve as it moves through committee study and public consultation. As such, while it may be early days for businesses to undertake full-scale operational changes, merchants offering event tickets, subscription services, or other forms of sequential performance should be prepared for material compliance updates that are likely to resemble the framework set out in the current draft.

If enacted as proposed, Bill 10's amendments would come into force in staggered phases, with all provisions taking effect within three months of receiving royal assent. With such a short implementation timeline, businesses should not wait to assess their current practices and identify potential gaps in their ticketing processes, online disclosures and cancellation flows. Early preparation will make it easier to adapt quickly once the final version of the law is published.

Read the original article on GowlingWLG.com

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