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Since December 17, 2025, Quebec enterprises employing 25 or more employees in the province must now provide proof of compliance with the francization process under the Charter of the French Language (the "Charter") when submitting a Labour Market Impact Assessment ("LMIA") for a position in Quebec. Enterprises must also commit to informing temporary foreign workers of available francization services to support their learning of the French language.
New French language requirements for foreign workers hired under the Temporary Foreign Worker Program (TFWP) in Quebec were also announced.
Who is affected?
Any enterprise operating in Quebec that employs 25 or more employees over a six‑month period must comply with these new requirements. Since June 1, 2025, these enterprises are subject to the francization process under the Charter and must therefore register with the Quebec French Language Office (the "OQLF") to begin the francization process.
Within three months of the date on which the certificate of registration is issued, the registered enterprise must transmit an analysis of its linguistic situation to the OQLF. The OQLF will then determine if the use of French is already generalized at all levels of the enterprise or if a francization program must be implemented.
What must be filed with the LMIA application?
At the time of filing an LMIA application for a position in Quebec, affected enterprises must include one of the following documents, based on their current stage in the francization process:
- An attestation of registration issued within the last three months;
- An acknowledgment of receipt from the OQLF regarding the linguistic situation analysis issued within the last 12 months;
- An attestation of application of a francization program that is already in effect; or
- A certificate of francization.
If none of these documents are available, the enterprise must obtain a letter from the OQLF certifying their compliance with the francization process.
Enterprises that do not comply with these requirements may see their LMIA application refused by the Government of Quebec.
To hire a foreign worker in Quebec through the TFWP, in addition to an LMIA application, there must be a concurrent application for a Quebec Acceptance Certificate (CAQ) filed with the Government of Quebec. A CAQ is needed in addition to the federal LMIA. Employers must usually demonstrate that they have met stringent recruiting requirements to find a qualified Canadian candidate, before applying, unless the occupation is listed in Quebec's facilitated list of occupations in high demand. The facilitated list is updated annually in February.
Other employer requirements
In addition to the documentation listed above regarding the francization process, all enterprises submitting an LMIA application must now inform newly hired temporary foreign workers of the French‑language learning services available in Quebec. Enterprises may meet this requirement by referring workers to the free government‑issued French courses.
New French proficiency requirements
In addition to the above requirements, Quebec announced that starting December 17, 2025, foreign workers who have three or more years of work experience in Quebec will need to show that they have French oral proficiency equivalent to Level 4 under the NCLC language benchmark to apply for a LMIA/CAQ.
There is a transition period for foreign workers already in Quebec. For such workers, the language requirement will need to be shown if applying for a LMIA/CAQ after December 17, 2028. Therefore, such foreign workers should take steps to ensure that they will meet the French oral language requirement in case they need to apply for a new LMIA/CAQ after the transition period.
The language requirement does not apply to agricultural workers.
Key takeaways
It will be important for Quebec enterprises to act promptly with these new requirements by confirming their status with the OQLF, gathering the appropriate supporting document for each LMIA/CAQ submission, and planning how they will inform temporary foreign workers about available French language services.
Employers with LMIA-based work permit holders in Quebec must also be aware of the new French speaking requirements and should take steps to ensure that current LMIA-based work permit holders develop the required level of oral French to enable future extensions to be obtained.
Read the original article on GowlingWLG.com
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