Quebec Law 25 (automated decisions and biometrics): requirements, deadlines and compliance actions
Quebec Law 25 (S.Q. 2021, c. 25): provisions on decisions based exclusively on automated processing and biometric systems
What is Quebec Law 25 (automated decisions and biometrics)?
Section 12.1 of the private-sector privacy act (as amended by Law 25, in force 22 September 2023) requires any enterprise that uses personal information to render a decision based exclusively on automated processing to inform the person no later than when the decision is made, and, on request, to tell them what personal information was used, the reasons and principal factors and parameters, and their right to have the information corrected, and to give them an opportunity to submit observations to a person who can review the decision. Biometric identification databases must be declared to the Commission d'accès à l'information 60 days before use, and privacy impact assessments are mandatory for projects involving personal information. Penalties reach CAD 25 million or 4% of worldwide turnover.
Who does it apply to?
Enterprises and public bodies in Quebec using personal information in exclusively automated decisions or biometric systems.
When do the requirements apply?
2021-09-22: assented; 2022-09-22: first provisions; 2023-09-22: automated-decision provisions in force; 2024-09-22: data portability.
Dates are taken from the linked official source; a reviewer should confirm in-force and application dates before relying on them.
Penalties
Administrative monetary penalties up to CAD 10 million or 2% of worldwide turnover; penal fines up to CAD 25 million or 4% of worldwide turnover.
Official sources
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S.Q. 2021, c. 25
Publications Québec · 22 Sep 2021 · Tier 1 source
Change history
Record version 1: Added in the September 2026 global coverage expansion from the official source listed; reviewer to confirm dates, status and scope against the source text.. Full edit history is in the GitHub repository.
Informational only, not legal advice. Verify every claim against the linked official sources and consult qualified counsel before acting.