On August 13, 2026, Québec introduced substantially increased minimum fines for specific contraventions of the Environment Quality Act (the “EQA”). These increased fines only apply to certain prescribed industries, including several in the manufacturing sector. As a result, proponents in industries impacted by these amendments face substantially increased financial exposure.
This bulletin provides an overview of the increased fines and impacted industries subject to these amendments and concludes with key takeaways for businesses.
Increased Minimum Fines
In 2025, Québec passed Bill 81 which amended various provisions of the EQA.1 These amendments allowed for minimum fines ten times higher than the otherwise applicable minimum fine for any person, other than a natural person, who commits certain prescribed offences in the course of carrying out a regulated activity.2 The prescribed offences subject to the increased fines include, among others, the release of contaminants into the environment, carrying out an activity without the requisite authorization, failure to comply with the standards or conditions of an authorization, the provision of false or misleading information, and failure to comply with an order, a rehabilitation plan, or certain remedial measures.3 Examples of these increased fines include:4
| Activity | Previous Minimum Fine | Increased Minimum Fine |
| Failure to comply with a condition of a ministerial authorization | $7,500 | $75,000 |
| Conducting an activity without ministerial authorization | $15,000 | $150,000 |
| Discharge of a contaminant into the environment | $15,000 | $150,000 |
To implement this amendment, on August 13, 2026, the Québec government amended the Regulation respecting the regulatory scheme applying to activities on the basis of their environmental impact to designate activities subject to these increased fines. Impacted industries include the following:
- Battery industry;
- Oil refineries;
- Pulp and paper industry;
- Mining;
- Aluminum smelters;
- Foundries;
- Cement plants;
- Steel manufacturing;
- Lime production; and
- Manufacturers of chemical fertilizers, explosives, tires, and glass.
According to the Québec government, these industries were specifically targeted due to the significant risk of environmental releases as a result of their environmentally sensitive operations.5
These changes are intended to target high-risk industrial activities, deter non-compliance, and more accurately reflect the environmental risk that the prescribed activities pose.6
Looking Forward
While the compliance obligations under the EQA have not changed, the consequences for such violations in Québec have increased. Affected businesses should review their compliance frameworks and status as having proper systems in place with commensurate training programs is the best way to ensure compliance and avoid potential fines.
Footnotes
1. Bill 81, An Act to amend various provisions relating to the environment.
2. Ibid at s 159.
3. Ibid at s 159.
4. Quebéc, Environnement, Lutte contre les changements climatiques, Faune et Parcs, “Infractions environnementales: des amendes minimales dix fois plus élevées pour les industries qui présentent les risques les plus importants” (12 August 2026).
5. Ibid.
6. Ibid.
The foregoing provides only an overview and does not constitute legal advice. Readers are cautioned against making any decisions based on this material alone. Rather, specific legal advice should be obtained.
© McMillan LLP 2025
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