Mr. Chair, members of the committee,
thank you for the opportunity to appear before you today.
For nearly five decades, Canadian Parents for French has worked to ensure equitable access for all Canadians to have opportunities to learn and use French, and to advance the full recognition and use of both official languages across our country. Today, we are here because the draft regulations under part VII of the Official Languages Act represent a pivotal moment. The modernization of the act was meant to move from aspiration to enforceable obligation and from uneven implementation to substantive equality.
Part VII clearly affirms two interdependent commitments: “(a) enhancing the vitality of [official language] minority communities” and “(b) fostering the full recognition and use of both English and French in Canadian society.” Part VII was always built on both minority protection and majority engagement, ensuring that OLMCs thrive and that Canadians in majority language contexts can embrace both official languages.
Our central concern today is this: As currently drafted, the regulations operationalize one pillar more clearly than the other. They translate institutional obligations into important processes: analyze, consult, document, report. However, when the act articulates two equal objectives, the regulations risk creating asymmetry. The draft regulations require detailed sectorial analysis when assessing impacts on OLMCs, yet no comparable analysis is required for the sectors and organizations that sustain societal bilingualism. If minority vitality warrants explicit examination of its institutional ecosystem, then the full recognition and use of English and French across Canadian society must be afforded the same structural attention.
A second concern relates to the repeated use of the term “other stakeholders”. The draft regulations refer to “other stakeholders” alongside OLMCs, but they do not define who those stakeholders are. In the absence of clarity, identification is left to administrative discretion. Experience has shown that when guidance is broad and definitions are absent, implementation varies and certain objectives are deprioritized. This is not a theoretical concern. When duality-focused organizations are not explicitly recognized as core actors under part VII, their participation becomes contingent rather than guaranteed. We are not asking to compete with OLMCs. We are asking that Parliament's full vision be implemented faithfully and coherently.
As a third concern, we must address capacity. National OLMC organizations receive dedicated public policy service support project funding that allows them to participate fully in policy and regulatory consultations. Duality-focused organizations generally do not, and they are often funded primarily for service delivery. Requiring participation without providing capacity undermines meaningful engagement and risks entrenching a system in which societal bilingualism is treated as secondary.
Finally, we urge the adoption of differentiated consultation mechanisms. There are hundreds of OLMC organizations across Canada. There are comparatively few organizations whose mandate is to foster the full recognition and use of English and French in Canadian society as a whole. When grouped together in undifferentiated consultation processes, the perspectives of duality-focused organizations can be overshadowed simply by volume. An undifferentiated framework does not reflect the dual commitments embedded in subsection 41(1). If the objectives are distinct, the consultation mechanisms must also be distinct.
In short, we urge having regulations that explicitly recognize societal linguistic duality as an equal objective of part VII, clarify that “other stakeholders” includes organizations advancing subsection 41(1), recognize duality-focused organizations as core actors, provide the structural supports necessary for meaningful participation and ensure direct consultation frameworks for duality-focused organizations. Regulations are not a technical afterthought. They are the instrument through which Parliament's intent is translated into operational reality. The regulations can either entrench ambiguity and uneven application or provide the clarity, symmetry and structural supports required to fully realize the modernization of part VII.
The opportunity before us is not simply to regulate. It is to complete the work of modernization with coherence, intention and fidelity to Parliament's full vision. The act is not only about protecting OLMCs, although this remains essential; it is also about shaping the linguistic character of Canada as a whole. We respectfully urge you to ensure that both pillars of part VII stand on equal footing so that substantive equality between English and French is not only promised in law but fully realized in practice.
Thank you very much.