Law 25 vs Bill 96: Which Quebec Law Governs Your AI Customer Service?

If you run a business in Quebec and you're adding an AI agent to handle customer chat, two laws land on your desk at once — and most owners think they're the same thing. They're not. Bill 96 governs the language you serve customers in and is enforced by the OQLF, while Law 25 governs the personal data your AI handles and is enforced by the CAI. Filing French complaints with the OQLF jumped to 10,371 in 2024-2025, up 14% in a single year (OQLF Annual Report 2024-2025). This guide separates the two laws cleanly and shows exactly where your AI customer service tool triggers each one.

What is the difference between Law 25 and Bill 96 in Quebec?

Bill 96 is Quebec's language law and Law 25 is Quebec's privacy law — they are separate statutes, with separate enforcers, that happen to both apply to any AI agent serving Quebec customers. Confusing them is the single most common mistake Quebec SME owners make when they research compliance, because online articles often treat the two as one topic.

Bill 96 (Law 14, 2022) amends the Charter of the French Language, the 1977 statute most people still call Bill 101. It controls the language of your service, your website, your invoices, and your communications. It is enforced by the Office québécois de la langue française, the OQLF.

Law 25 (formerly Bill 64, 2021) is the Act to modernize legislative provisions as regards the protection of personal information. It is GDPR-style privacy law, and it controls how you collect, store, and move personal information — including the chat transcripts your AI agent generates. It is enforced by the Commission d'accès à l'information du Québec, the CAI. Different law, different regulator, different penalties.

The practical takeaway is to run two separate checklists. A bilingual AI agent helps you satisfy Bill 96. The way that agent stores and routes data is what satisfies Law 25. One tool, two compliance problems.

Does Bill 96 require my AI agent to answer customers in French?

Yes. If a customer writes to your AI agent in French, you must reply in French — and that obligation extends to chat, social media, and messaging channels, not just signage. This is the rule most directly relevant to conversational AI, and it is where a poorly configured agent creates legal exposure rather than just a service hiccup.

Under the Charter as amended by Bill 96, consumers have the right to be informed and served in French, and any business with five or more employees must be able to serve customers in French (Éducaloi, 2026). The flip side matters too: if a customer writes to you in another language, you may reply in that language. So your AI agent's job is accurate per-message language detection, then a native response in the customer's chosen language.

The demand is real and rising. Of all OQLF complaints in 2024-2025, the share relating to "langue de service" — language of service — climbed from 25% to 40% over five years (OQLF Annual Report 2024-2025). Serving a French customer in English is now the single largest complaint category. That's no longer just a bad-experience problem; it's the thing regulators hear about most.

Enforcement has teeth. OQLF fines run $3,000 to $30,000 per day for a first offence, doubled for a second offence and tripled for subsequent ones (Éducaloi, 2026). For an SME, a sustained language-of-service failure across an always-on chat channel is exactly the kind of repeatable, documentable lapse that compounds.

When does Law 25 apply to a chatbot or AI customer service tool?

Law 25 applies the moment your AI agent collects, stores, or processes personal information about a Quebec resident — which is essentially every chat that includes a name, phone number, email, or address. Because chat transcripts almost always contain personal information, Law 25 is in play for any AI customer service deployment, full stop.

Three Law 25 obligations bite hardest for AI tools. First, consent and transparency: you must tell people what you collect and why, and automated decision-making carries its own transparency duties. Second, breach notification and a designated Privacy Officer, which defaults to your highest-ranking person unless you formally assign someone else. Third — and this is the AI-specific landmine — a Privacy Impact Assessment, or PIA, before transferring personal information outside Quebec.

That third point is where AI vendors trip up owners. Many AI platforms process or store data on servers outside Quebec. Under Law 25, sending personal information out of the province requires a PIA that weighs the sensitivity of the data, the purpose, and the protections in the destination jurisdiction. If your AI tool ships transcripts to a data center in another province or country, that assessment is your responsibility, not the vendor's.

The penalties dwarf the language fines. Law 25 violations can reach the greater of $25 million or 4% of worldwide turnover (Law 25 / Bill 64, 2021). In practice the CAI is unlikely to drop a $25M penalty on a plumbing company, but the figure tells you how seriously Quebec treats privacy — and why "we'll sort out data residency later" is the wrong attitude when you pick a vendor.

Law 25 also hands customers rights that an AI deployment has to honor: access to their information, rectification, portability, de-indexation, and the right to object to automated decision-making. If your AI agent makes any decision that affects a customer without a human in the loop, you owe them transparency about it. For most SME chat use — answering questions, capturing leads, booking appointments — you're well inside safe territory, but it's worth knowing the line exists before you wire the agent into anything that approves, prices, or rejects automatically.

Law 25 vs Bill 96: a side-by-side comparison

The fastest way to keep these straight is to see them next to each other. The table below maps each requirement to its specific legal basis and its enforcer, so you know who to satisfy and why.

Read the table as two columns of obligations that run in parallel. A perfectly bilingual AI agent that quietly ships every French transcript to a US server is Bill 96 compliant and Law 25 non-compliant. An agent hosted entirely in Quebec that answers French customers in English is the reverse. You need both columns green.

Sources for the figures in this table appear at the end of the article. The point of laying it out this way is simple: when a vendor tells you they "handle Quebec compliance," ask which column they mean.

How good does the French actually have to be?

The French has to be of a quality "at least equivalent" to your other-language version — the OQLF explicitly cautions businesses against relying on raw machine translation for commercial publications because the output may not meet its bar. For an AI agent, this means a generic model that produces literal or France-centric French is a compliance and credibility risk, not just an awkward read.

Quebec French differs from France French in vocabulary and idiom that local customers notice immediately. Quebecers say "magasiner" for shopping and "stationnement" for parking, where a France-trained model might default to "faire du shopping" or "parking." Authentically Québécois phrasing signals that you actually serve the local market.

Register matters as much as vocabulary. Quebec is more open to tutoiement — the informal "tu" — than France, even in some first-contact commercial settings, but vouvoiement (the formal "vous") remains the safe default for service interactions, older customers, and formal trades. A well-configured AI agent should default to "vous" on first contact and a professional service tone, then follow the customer's lead.

This quality bar is not theoretical. Since 1990 the OQLF has run its Mérites du français awards, including a "Langue de commerce" category that rewards the quality of French-language service across channels — online ones included. Regulators are watching whether your French is good, not merely present. When you evaluate an AI vendor, test it with real Quebec French phrasing before you trust it with customers.

There's a workforce reality underneath all this, too. In 2021, 6,581,000 Canadians (18.0%) could hold a conversation in both official languages, and in Quebec the bilingualism rate was 46.4%, up from 44.5% in 2016 (Statistics Canada, 2021 Census). That sounds like a healthy pool — until you try to hire bilingual front-line staff who can also write clean, professional Quebec French at 11 p.m. on a Saturday. The reason a single AI "brain" beats duplicate bilingual desks is that it holds one knowledge base, one set of business rules, and one escalation logic, then simply renders the conversation in the customer's language. You're not staffing two language teams or routing French callers to a unilingual English voicemail; you're maintaining one source of truth that speaks both languages consistently. That consistency is itself a compliance asset, because it removes the channel-to-channel drift the OQLF flags.

What are the common AI language-routing mistakes to avoid?

The most damaging mistake is "sticky language" — when the agent locks onto the language of the first message and refuses to switch when the customer does. A customer who opens with "Hi" out of habit then continues in French should get French immediately. An agent that keeps replying in English has just created the exact langue-de-service failure the OQLF logs most.

Here are the failure modes a well-built AI agent has to avoid:

1. Serving a French customer in English — now the single largest OQLF complaint category, a legal risk and not just a service lapse.
2. Detection errors on short or code-switched messages — a one-word "Oui" or a mixed "Bonjour, can you help?" trips up weak language detection.
3. Sticky-language bugs — the agent commits to the first detected language and won't follow the customer when they switch.
4. Inconsistent language across channels — French on web chat but an English confirmation, which fragments the experience and the compliance record.
5. France-centric French — technically French, but foreign-sounding to Quebec customers and below the OQLF quality bar.

The fix is a combination of per-message language detection, an explicit and easy language toggle the customer can use, and a sensible default: treat any Quebec-based contact as French-first unless they clearly opt into English. This is straightforward to configure with a modern AI agent platform — Omago, an AI agent platform that helps SMEs automate customer conversations across WhatsApp, Telegram, and web chat, detects language per message and holds one bilingual knowledge base so the EN and FR experience stays consistent.

One more honest caveat: AI handles the routine bilingual interaction well, but it should not be the last line on anything carrying legal or safety weight. For complaints requiring resolution authority, distressed customers, or anything touching liability, the agent's job is to escalate cleanly to a human — not to improvise. Good automation knows what to route. For deciding that split, our guide on when to automate versus hire walks through the line in detail.

How do I make my AI agent compliant with both laws at once?

Treat compliance as two checklists you complete in parallel, then verify the same tool satisfies both before you go live. The Bill 96 checklist is about language behavior; the Law 25 checklist is about data behavior. Most owners do one and assume the other is covered — that's the trap.

For Bill 96, confirm your AI agent does per-message language detection, defaults Quebec contacts to French, responds in authentic Quebec French of equivalent quality, and keeps the same language across every channel including confirmations. Test it with real French phrasing and short messages before launch.

For Law 25, find out where the vendor stores and processes transcripts. If personal information leaves Quebec, run a Privacy Impact Assessment before launch, capture clear consent in the chat flow, name your Privacy Officer, and have a breach-notification process ready. Ask the vendor directly: where does my data live, and who can see it?

A quick note on the federal layer, because it confuses people. The federal Official Languages Act (1969) binds federal institutions, not private SMEs. The newer Use of French in Federally Regulated Private Businesses Act is enacted but not yet in force; once proclaimed it will cover telecoms, banks, and interprovincial transport in Quebec — not most local home-services or retail businesses. For the typical Quebec SME, the operative language law is the Charter via Bill 96, and the operative privacy law is Law 25. If your data and privacy obligations span the rest of Canada too, our overview of PIPEDA and Law 25 customer data rules covers the federal side.

Frequently Asked Questions

Is Law 25 the same as Bill 96?

No. Law 25 is Quebec's privacy law, enforced by the CAI, and it governs how you handle personal information including chat transcripts. Bill 96 is Quebec's language law, which amends the Charter of the French Language and is enforced by the OQLF. An AI customer service tool triggers both because it processes personal data and communicates in a chosen language.

Do I legally have to serve Quebec customers in French through chat?

Yes, if your business has five or more employees and serves Quebec consumers. Under the Charter of the French Language as amended by Bill 96, customers have the right to be served in French, and if a customer writes to you in French you must reply in French — that applies to web chat and messaging, not only physical signage (Éducaloi, 2026).

What happens to Law 25 if my AI vendor stores data outside Quebec?

You must complete a Privacy Impact Assessment before transferring personal information outside Quebec. The PIA weighs the data's sensitivity, the purpose of the transfer, and the protections in the destination jurisdiction. This obligation falls on you as the business collecting the data, so confirm your vendor's data residency before you sign anything.

Can machine translation satisfy the French-quality requirement?

Not reliably. The OQLF cautions against relying on raw machine translation for commercial publications because the output may not meet its quality bar, which requires French "at least equivalent" to the other-language version. For an AI agent, that means using a tool tuned for authentic Quebec French — proper vocabulary, register, and idiom — rather than a generic model that produces France-centric or literal phrasing.

How large are the fines under each law?

OQLF fines for Bill 96 language violations run $3,000 to $30,000 per day for a first offence, doubled for a second and tripled for subsequent offences (Éducaloi, 2026). Law 25 privacy penalties can reach the greater of $25 million or 4% of worldwide turnover (Law 25 / Bill 64, 2021). The scale of the privacy penalty reflects how seriously Quebec treats personal information.

Sources: OQLF / Government of Quebec Annual Report 2024-2025 (2025), Éducaloi (2026), Law 25 / Bill 64 — Act respecting the protection of personal information in the private sector (2021), Charter of the French Language as amended by Bill 96 / Law 14 (2022), Official Languages Act (1969), Statistics Canada 2021 Census (2022).