French in the Workplace: What Federal Employers Need to Know

On April 15, 2026, the Government of Canada published a preliminary draft regulation under the Use of French in Federally Regulated Private Businesses Act (“UFPBA”). Enacted in 2023 through Bill C-13, this Act has not yet come into force. This draft regulation aims to clarify and concretely outline the scope of the UFPBA. Here are the key points to bear in mind. 

The UFPBA grants various rights to employees and consumers of private companies under federal jurisdiction. 

In the workplace, this law has a clear goal: strengthening the use of French as both the language of work and of service within private companies under federal jurisdiction. This framework will apply not only in the province of Québec, but also in other parts of Canada with a strong French-speaking community. 

French in the Workplace: What the UFPBA’s Draft Regulation Clarifies 

The draft regulation aims, among other things, to clarify several aspects related to the application of the UFPBA. These include the designation of regions with a strong Francophone presence (“RSFP”) outside of Québec, the threshold number of employees required for a company to be subject to the Act, applicable rules regarding the provision of services and signage, the language rights granted to employees, and the administrative obligations required of employers. Some sectoral or functional exemptions are also provided for. 

According to the announced approach, the UFPBA would first come into force in the province of Québec, then be extended to the RSFPs two years later. 

Which federal businesses will be subject to the new rules on French in the workplace? 

In the province of Québec, the UFPBA will apply to private companies under federal jurisdiction with 25 or more employees in the province. Outside the province of Québec, only companies operating in a RSFP and with at least 100 employees nationwide will be subject to the UFPBA. 

However, some exemptions are provided for, particularly regarding First Nations peoples and businesses. The preliminary draft regulation also provides for exclusions for certain non-French-language cultural activities and for contexts where the use of a language other than French is justified by the very nature of the activities, such as research or international endeavours. 

Businesses subject to the UFPBA, both in the province of Québec and in the RSFPs, will have to file an initial declaration detailing their operations, confirm or update this information annually with the Minister of Canadian Heritage, and in return will be issued an annual registration certificate. 

The Choice Between the Federal Regime and the Charter of the French Language in the province of Québec  

In the province of Québec, application of the Charter of the French Language (“the Charter”) to private enterprises under federal jurisdiction is a complex issue. For one thing, since 2022, Bill 96 has introduced Section 89.1 of the Charter so that certain rules regarding the language of work apply to any business or employer operating in the province of Québec, regardless of which jurisdiction it falls under. The Office québécois de la langue française (“OQLF”) already includes businesses under federal jurisdiction in its resources on the francization process. Furthermore, the constitutional application of these provisions remains uncertain and could be subject to legal challenges. 

Meanwhile, the UFPBA provides that it will apply by default to federal-jurisdiction businesses in the province of Québec, unless they choose to be subject to the Charter instead, in which case they may be exempt from the application of the UFPBA under its section 6. 

Federal enterprises that have already voluntarily registered with the OQLF under the Charter may choose to remain under that regime or switch to the federal regime. As for businesses with 25 or more employees in the province of Québec wishing to register with the OQLF rather than be subject to the UFPBA, they must notify the Minister of Canadian Heritage in writing to that effect. 

Regions with a strong Francophone community targeted elsewhere in Canada 

The designation of RSFPs aims to target areas where the potential demand for French-language services is sufficiently high, and where the private-sector workforce is able to meet that demand. 

The preliminary draft regulation will define RSFPs based on demographic criteria derived from Statistics Canada’s 2021 census data and consultations carried out by the government. 

For now, these regions are considered RSFPs: 

• New Brunswick (the entire province) 
• Nova Scotia (the following census divisions: Yarmouth, Digby, and Richmond) 
• Ontario (the following census divisions: Stormont, Dundas and Glengarry, Prescott and Russell, Ottawa, Nipissing, Sudbury, Greater Sudbury, Timiskaming, and Cochrane). 
• Manitoba (21 census tracts located east and south of the Winnipeg Census Metropolitan Area) 
• Alberta (the census tract encompassing the University of Alberta’s Saint-Jean Campus in the Edmonton Census Metropolitan Area) 

Employees' Rights Related to French in the Workplace 

In workplaces, both in the province of Québec and in the RSFPs, the UFPBA will grant employees the following rights, among others: 

• the right to perform their work and be supervised in French; 
• the right to receive essential communications and documents related to their employment in French, including job offers, employment contracts, training materials, documents regarding working conditions, notices of termination, and collective bargaining agreements; 
• the right to use work tools and computer systems in French. 

The UFPBA will also provide for the establishment of committees to promote the use of the French language. In the province of Québec, federal-jurisdiction companies with 100 or more employees will be required to form such a committee. Outside the province of Québec, this requirement will apply to companies with at least 100 employees across all federal-jurisdiction regions and at least 500 employees in Canada. 

Specific rights are also recognized in collective bargaining and arbitration proceedings, including the obligation to translate decisions promptly if requested by an employee or a union, and to provide documentation and communications in French to a union that acts on behalf of employees of a private company under federal jurisdiction working in a workplace located in the province of Québec or in an RSFP, upon request. 

Finally, for companies with a place of business in the province of Québec, additional requirements would apply, including: 

• the obligation to post job openings in French simultaneously and through the same channels as any version in another language; 
• the obligation for the committee promoting the use of the French language to provide a report on the language situation to qualify for a certificate attesting to the widespread use of French; 
• prohibition of any unfair treatment towards an employee due to the exercise of a right provided for in the UFPBA or because they do not speak a language other than French, except when knowledge of that other language constitutes a justified requirement related to the job. 

Key Takeaways 

Although the UFPBA is not yet in effect, its regulatory framework is quickly taking shape. Here are the key points to remember: 

• In the province of Québec, private companies under federal jurisdiction will have to choose between the federal and provincial regimes—a strategic choice that warrants thorough analysis. 
• The potential application of the UFPBA will depend on how many employees a company has and where its operations are located. 
• Employers with business in the province of Québec or in the RSFPs would be well advised to review their language practices and assess whether their number of employees could trigger the application of the UFPBA. 

Do you have questions about how the UFPBA will affect your business ?

If you have any questions about how the UFPBA will affect your business, an early assessment of your internal practices, workforce, and applicable obligations can help you identify potential challenges related to its implementation. Our labour and employment law team can assist you with your francization efforts and help manage any related issues.