Most Bill 96 coverage written for employers is about signage and customer-facing contracts. If you run HR, that is not where your exposure is. Yours is in the documents you send a candidate, the contract you ask someone to sign, the training material you push out, the announcement you post to the whole company, and the tools your team types all of that into. Those are the things the Charter of the French Language actually names, and the threshold for the heaviest obligation moved last year.
The number that changed: 25, not 50
The Charter of the French Language, as amended by Bill 96 (Law 14), requires businesses of a certain size operating in Quebec to register with the Office quebecois de la langue francaise and go through a francisation process. That threshold used to be 50 employees. As of June 1, 2025 it is 25. A company with 25 to 49 people in Quebec that previously had no registration obligation now has one, and a lot of them are still working through it.
Registration is not the end of it. The Office reviews the use of French across the business and either issues a francisation certificate, if French is already sufficiently generalized, or requires a francisation program to get there. A francisation program is explicitly about generalizing French at all levels of the enterprise, and that expressly includes information technologies, which is where an HRIS lands.
The HR documents the Charter names by category
This is the part worth pinning to your own process, because these are named categories rather than a vague duty to be accommodating. Employers are required to provide the following in French:
- Offers of employment, and offers of transfer or promotion.
- Individual employment contracts.
- Job application forms.
- Documents concerning conditions of employment.
- Training documents produced for staff.
- Written communications with employees, and with the association representing them.
There is a narrow exception: an employer may communicate with a particular worker exclusively in another language where that worker has asked for it. Note the direction of that exception. It is the employee’s request, recorded, not the employer’s convenience, and it is per person rather than a blanket setting for an office.
Job postings, and asking for a language other than French
You may still hire for a role that requires English or another language. What you may not do is require it casually. The employer has to take reasonable means to avoid imposing the requirement, which in practice means assessing what the role genuinely needs, checking whether existing staff already cover it, and keeping the number of such positions to what is actually necessary. Where a posting does require another language, it has to state the reasons why.
The practical consequence for HR is a record-keeping one. If you cannot show the assessment happened, you are relying on the reasonableness of a decision nobody wrote down. Whatever system holds your requisitions should hold that reasoning next to them.
Where software fits, and a common misreading
The obligation around technology is frequently overstated in both directions. It is not true that every tool must be French-only, and it is not true that software is out of scope. The workable summary: French has to be genuinely available as a working language across the tools your staff use, and nothing stops you from also offering another language alongside it. A tool that cannot present itself in French to a French-speaking employee is a problem. A tool that offers both is not.
The test worth applying when you evaluate an HRIS is narrower and more useful than "is it bilingual", a claim every vendor makes. Ask these four instead:
- Is language a per-EMPLOYEE setting, or one setting for the whole company? A single company-wide toggle fails the moment you have a Montreal team and a Toronto team in the same tenant.
- Does the EMPLOYEE-facing app translate, or only the HR admin screens? Employees are the population the Charter is protecting. An HRIS whose admin console is bilingual and whose self-service app is not has translated the wrong half.
- Do transactional emails go out in the RECIPIENT’s language, or in the sender’s? This is the one buyers forget, and it is the surface that reaches people who have never logged in.
- What happens to content YOUR team writes: an announcement, a policy, an onboarding task list? Does the tool store one version or two?
Where Workleaf stands on those four, precisely
We would rather answer this specifically than claim to be "fully bilingual" and let you find the edges later. On the first three: language is a per-employee setting, so two people in the same company can see the same record in different languages; both the HR admin app and the employee self-service app are EN-CA and FR-CA throughout, not just the admin side; and transactional email is sent in the recipient’s language, with the language chosen by a human when the recipient has never logged in and so has no preference on file yet.
On the fourth, the honest answer is that the content you write is stored as you write it. If an HR admin composes a company announcement in English, Workleaf stores that English text and shows it to everyone, including employees whose interface is in French. The interface around it translates; the words you typed do not. Supporting a French and an English version of the same announcement is on our roadmap and is not shipped today, so if you are relying on that for a Charter obligation, plan on writing both versions yourself for now. We would rather you hear that from us than discover it in month two.
What non-compliance costs
For a company, a first offence carries a fine in the range of $3,000 to $30,000, with higher ranges for repeat offences, and days can be counted separately. The more realistic risk for most mid-sized employers is not a maximum fine, it is the francisation process going badly because nobody could produce evidence of what was communicated, in what language, to whom.
That is worth sitting with, because it is a records problem more than a translation problem. Retention rules already require you to keep employee records for years, and the Charter adds the question of what language those records were in.
A short checklist you can run this week
- Count your Quebec headcount. If it is 25 or more, confirm your registration status with the Office rather than assuming the old 50-employee threshold still applies to you.
- Pull your last ten offers of employment and your standard employment contract. Were they issued in French?
- Open your most recent company-wide announcement. What language is stored, and who received it?
- Check your last five job postings. Do any require a language other than French, and if so, do they state why?
- Ask your HRIS vendor the four questions above and get the answers in writing, particularly the difference between the admin app and the employee app.
None of this is legal advice, and the Charter has more surface than one article can cover. Confirm your own position against the Office’s guidance or with counsel, especially if you are newly over the 25-employee line.