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Car and recreational vehicle dealers as well as the insurance sector are facing a major legislative change introduced by Bill 30, enacted as Act 15 (An Act to amend various provisions mainly with respect to the financial sector).
As mentioned in our May 16, 2024, newsletter, a key measure of this reform is the prohibition for "distributors" — including automobile and recreational vehicle dealers — from offering replacement insurance (Q.P.F #5) related to vehicles they sell or lease.
Updated schedule
On February 26, the National Assembly of Québec adopted Bill 11 (An Act to amend various provisions mainly for the purpose of reducing the regulatory and administrative burden). Among its measures, the bill amends the coming into force of section 110 of Act 15 to exclude replacement insurance from the products that distributors may offer. The implementation of this amendment has been deferred until January 1, 2027.
Amendment to Act 15
The entry into force of the legislative amendment in section 110 of Act 15, originally scheduled for July 1, 2026, has now been officially postponed to January 1, 2027.
This postponement provides insurers and other industry stakeholders with additional time to adjust their business models, and gives them the opportunity to realign their replacement‑insurance distribution networks.
Impact on customers and dealers
Effective January 1, 2027, automobile and recreational vehicle dealers will no longer be permitted to distribute replacement insurance. This product must instead be obtained through licensed firms and representatives in Québec, such as agents or property and casualty insurance brokers. Other insurance products lawfully offered by dealers are not affected by this change.
Until the new deadline, current sales practices remain authorized under the Act respecting the distribution of financial products and services.
Legislative references:
- Bill 30 (Tabled June 7, 2023).
- Act 15 (SQ 2024, c. 15; assented May 9 2024).
- Amendments to the Act respecting the distribution of financial products and services: (CQLR, c. D-9.2).
- Bill 11 (passed on February 26, 2026)
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