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Bill 96 and public construction contracts: who can be awarded the contract, and which documents must be in French.

Since June 1, 2023, Bill 96 construction rules require a contract with a Quebec ministry, public body or municipality, and the documents tied to it, to be in French. A firm subject to francization must meet its obligations first. An English version may be attached in set cases; the French prevails unless the parties expressly agree otherwise.

Charter as consolidated, October 2026

This post sets out what the Charter of the French language says, article by article, as consolidated in October 2026. It is not legal advice: for your own contract, ask counsel. For the general rules on construction documents, see our guide to Bill 96 and construction documents.

Which owners does it apply to?

The civil administration, as Schedule I of the Charter defines it: the government and its ministries; government bodies, including those whose members are mostly named by the government or a minister; municipal bodies, from municipalities and metropolitan communities to transit authorities, housing offices and intermunicipal boards; school service centres; and health and social services bodies.

Federal owners in Quebec are not part of it. Their projects follow the Official Languages Act: see our guide to official languages on federal projects.

Schedule I: the civil administration

  • aThe government and its ministries
  • bGovernment bodies
  • cMunicipal bodies, transit authorities, housing offices
  • dSchool service centres
  • eHealth and social services bodies

Federal owners in Quebec→ Official Languages Act

Can my firm be awarded the contract?

Only if it meets its francization obligations. Under section 152.1, the civil administration may not enter into a contract with an enterprise that is subject to francization and lacks its certificate of registration, has not filed its language analysis on time, holds neither a francization program attestation nor a certificate, or appears on the Office’s list of non-compliant enterprises. Registration with the Office québécois de la langue française applies to an enterprise that has employed 25 or more people for six months (s. 139).

The Ministry of Municipal Affairs reads section 152.1 as covering every municipal contract, whatever its value and including contracts by mutual agreement, with the 25-employee threshold in force since June 1, 2025, and conformity required before the contract is entered into. The regulation allows an owner to contract with a non-compliant enterprise only when its mission would otherwise be compromised, and only in an emergency where the safety of persons or property is at stake, or when a sole supplier offers no equivalent; that exception ends on June 1, 2028.

Before the contract: s. 152.1

  1. A certificate of registration
  2. The language analysis filed on time
  3. A francization program attestation or certificate
  4. Not on the Office's list of non-compliant enterprises

The dates the post cites

  1. June 1, 2023Every document relating to a municipal contract in French (Ministry of Municipal Affairs).
  2. June 1, 2025The 25-employee francization threshold in force.
  3. June 1, 2028The emergency and sole-supplier exception ends.

Which project documents must be in French?

Three kinds, under sections 21 and 21.3:

01

The contract itself

including its related sub-contracts, drawn up exclusively in French.

02

The documents sent to enter into the contract

the bid, its forms and its supporting documents.

03

The documents related to the contract and those sent under it

by one party to another.

The Ministry of Municipal Affairs states that every document relating to a contract involving a municipal body has been in French since June 1, 2023. For contracts entered into before that date, ask counsel which obligations apply.

Article by article

s. 21
The contract and its related sub-contractsDrawn up exclusively in French.
s. 21.3
Documents sent to enter into the contractIn French.
s. 21.3
Documents related to the contract or sent under itIn French.
s. 21.4; Reg. s. 4
A version in another languageMay be attached in the cases the Charter and the regulation list.
Reg. s. 14
Which version prevailsThe French, unless the parties expressly set the legal value of each.
s. 21.10
Inscriptions on supplied productsIn French.
s. 21.11
Services obtained from a firmRequired in French.
s. 21.9; Reg. s. 6
Permit and authorization applicationsExclusively in French, with regulated exceptions.
s. 152.1
Eligibility for the contractFrancization obligations met before the contract is entered into.

Where the Charter puts each obligation (Charter of the French language, CQLR c. C-11, and its regulation on the language of the civil administration, r. 8.1)

Can you attach an English version?

Yes, in the cases the Charter and its regulation list. Section 21.4 allows a version in another language to be attached when the owner contracts in Quebec with a natural person not residing in Quebec, or with an enterprise that is not required to register in Quebec’s enterprise register and has its head office where French is not an official language, among other cases.

The regulation adds cases that matter on construction projects, among them:

  • Interesting firms with no establishment in Quebec in a public call for tenders.
  • Third-party documents with no French version a bidder or contractor may attach the other-language version of a technical, industrial, scientific, financial or insurance document that does not exist in French and was produced by someone else.
  • Products or services impossible to obtain in due time and at a reasonable cost in a compliant version.

Whenever both versions exist, the parties may set the legal value of each. If they do not say, the French version prevails (Reg. s. 14).

When can a document stay in English only?

In narrower cases. A contract the owner enters into outside Quebec may be in another language only (s. 21.5). A document relating to a section 21 contract may be in another language only if the owner consents and the document is authentic, semi-authentic, or has a legal value that would prevail over a French version (s. 21.6). Written communications needed to enter into a contract that may itself be in another language may be in that language (s. 21.8).

When a document is allowed in another language only, the owner makes a French version of the parts its staff need available to them (s. 21.7).

Where another language alone is allowed

  1. E-01A contract entered into outside Quebec.
  2. E-02A document the owner consents to and that is authentic, semi-authentic, or has a legal value that would prevail.
  3. E-03The communications needed for a contract that may itself be in another language.
  4. E-04The cases the regulation lists for attaching a version in another language; ask counsel whether the French is still required in yours.

What about equipment, manuals and services?

s. 21.10

Products

Every inscription on a product obtained under a supply contract, in French as section 51 requires.

s. 21.11

Services

Services obtained from a firm, required in French.

s. 21.12

Unless

A compliant product or equivalent cannot be obtained in due time, or services other than those to the public cannot be rendered in French.

For an equipment supplier, that reaches the product inscriptions delivered under the contract, not only the contract itself; ask counsel which documents supplied with the product section 51 covers on yours.

Do permit applications have to be in French?

Yes. The documents an enterprise sends to obtain a permit or a similar authorization, a subsidy or other financial assistance are exclusively in French, and so are the documents the holder must send because of it (s. 21.9). The regulation sets exceptions, for instance documents also sent to a third party outside Quebec, or sent from a head office outside Quebec (Reg. s. 6).

Where does the owner say when it uses English?

In its own directive. Each ministry, government body and municipal body subject to the government’s language policy adopts a directive on the situations in which it will use another language, revised at least every five years (s. 29.15). The directives of ministries and government bodies are published in the Ministère de la Langue française’s registry of directives; municipalities adopt and publish their own. Read the owner’s directive before you plan the language of a bid.

Before you bid

A bid checklist for public tenders under Bill 96

  1. 1Confirm your francization documents are in order before you bid, if your firm is subject to francization.
  2. 2Prepare the bid and its forms in French, with every supporting document.
  3. 3List the third-party documents with no French version, and ask counsel how the regulation lets you attach them.
  4. 4Read the owner’s language directive for the cases where it uses another language.
  5. 5Plan French manuals and product inscriptions if the contract supplies equipment.
  6. 6Settle the terms of the set once, so the bid, the contract documents and the manuals say the same thing.

Translating a bid into French under a tender deadline is what our tenders and bids service is built for. For a project’s other documents, see our French translation services, and on which French to use, our post on Canadian French vs French.

Common questions

Does Bill 96 apply to private construction contracts?
Sections 21 to 21.12 apply to dealings with the civil administration: ministries, public bodies and municipal bodies. Private contracts follow other parts of the Charter; see our guide to Bill 96 and construction documents.
Can my bid include English documents?
Your bid is in French. The regulation lets you attach the other-language version of a third-party technical document that does not exist in French, among other cases. Ask counsel whether a French version is still required in yours.
Which version governs if the French and English differ?
The French, unless the contract expressly sets the legal value of each version (regulation on the language of the civil administration, s. 14).
Do equipment manuals have to be in French on a public contract?
The inscriptions on a product obtained under a supply contract must be in French, as section 51 requires, unless a compliant product cannot be obtained in due time (ss. 21.10 and 21.12).