That's a good description of the situation. Yes, the new Official Languages Act has been in effect since June 2023. Personally, I don't work with every federal institution. I work mainly with Health Canada. I've seen Health Canada show leadership on this, by trying to define aspects of the act that were unclear, especially in relation to constructive policies or measures. The department came up with definitions internally of what may be meant.
At the end of the day, that doesn't make up for the lack of regulatory clarity, leaving each federal institution to come up with its own interpretation. Even when an institution shows leadership on a certain issue—I talked about the difference between taking measures to “promote” and “imposing obligations”—some things still aren't understood. Regulations are needed to ensure that everyone has the same understanding. Right now, everyone is groping along, trying to figure out how to meet their obligations.
As I see it, many of the obligations in the act are not being met, but it's important to put that in context. The link to Treasury Board is complex. It has a new role when it comes to official languages. There are many reasons why things are stalled.