Official Languages Committee on March 12th, 2026

[The Chair, Liberal, Yvan Baker]

Colleagues, welcome to meeting number 25 of the Standing Committee on Official Languages.

Pursuant to Standing Order 108(3)(f) and the order of reference of Tuesday, December 9, 2025, we are continuing our study of the official languages (advancement of equality of status and use of English and French) regulations.

I would now like to welcome our witnesses.

From Droits collectifs Québec, we have Étienne‑Alexis Boucher, chief executive officer; François Côté, lawyer; and Esther Poirier, articling student. All three are joining us by video conference.

Welcome.

From Canadian Parents for French, we have Derrek Bentley, network chief executive director; and Ahdithya Rajan P. Visweswaran, director, advocacy and public policy.

Welcome.

We also have Stéphanie Chouinard, associate professor, as an individual. She is joining us by video conference.

Each group will have five minutes for their opening remarks. Then we'll go to questions from members.

Mr. Boucher, you have the floor.

[Étienne-Alexis Boucher, Chief Executive Officer, Droits collectifs Québec]

Good afternoon, everyone. I hope you're doing well.

My name is Étienne‑Alexis Boucher. I am chief executive officer and co-founder of Droits collectifs Québec. We are an independent community action organization recognized by the Secrétariat à l'action communautaire autonome et aux initiatives sociales, or SACAIS, as a collective advocacy organization.

The main portion of our remarks will be delivered by Mr. Côté.

I just want to say this. In a few words, much ado about nothing. I remind you that we worked on reforming the Official Languages Act for more than a few years. In the case of the regulations currently under consideration, it took more than two years for the Government of Canada to produce a six-page document that unfortunately doesn't allow the Official Languages Act to comply with international law when it comes to determining which language group is considered a minority or a majority.

These regulations also do not respond to the science of protecting minorities, whereas when a state wants to protect a minority language, it invests in a region where that language is useful. I can tell you that when Switzerland is looking to protect the Italian language, it doesn't invest in German-speaking or francophone cantons. It invests in Italian-speaking cantons.

Finally, unfortunately, these regulations do not allow the government to respect the intent of the legislator, who recognized that French is in decline across Canada and that the federal government must therefore support it across Canada, including in Quebec.

Unfortunately, there were no new positive measures in the action plan for official languages 2018‑23 to support French in Quebec as well.

I will now yield to Mr. Côté.

[The Chair, Liberal, Yvan Baker]

I will now turn the floor over to Mr. Bentley for five minutes.

[Derrek Bentley, Network Chief Executive Officer, Canadian Parents for French]

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.

[The Chair, Liberal, Yvan Baker]

Thank you, Mr. Bentley.

I will now turn the floor over to Ms. Chouinard for five minutes.

[Stéphanie Chouinard, Associate Professor, As an Individual]

Thank you, Mr. Chair.

I would also like to thank the vice-chairs and members of the committee for inviting me to appear before the committee to discuss the draft regulations relating to part VII the Official Languages Act.

My remarks will echo many of the thoughts and briefs you have already heard from stakeholders since you began your work on this issue. The consensus is fairly unanimous: It is imperative to go back to the drawing board to ensure that the regulations not only set out processes. They must also set out objectives and the means for evaluating the achievement of these objectives, in terms of the vitality of communities and progress towards true equality for both official languages.

In their current state, the draft regulations will not prevent us from finding ourselves, in a few years' time, facing a Gascon 2.0 ruling. I probably don't need to remind you that the Federal Court ruled in this 2018 decision that the language of part VII did not impose any obligations as to results or concrete measures to advance substantive equality between the official languages.

This ruling was one of the main reasons that brought the need to modernize the Official Languages Act to the forefront of the political agenda. Much of the work done since 2018, particularly within your own committee, has been aimed at ensuring that the new version of the act would address this shortcoming.

Here are a few proposals aimed at revising the draft regulations to ensure that the implementation of the new version of part VII effectively meets the intent of lawmakers by setting out clear obligations for the federal government.

First, the regulations should spell out more precisely how and under what circumstances federal institutions are to determine the objectives of the policies implemented, which must be clear and measurable. In addition, they must take into account the priorities of communities.

They must also require federal institutions to be accountable for the measures they do or do not adopt, particularly following dialogues and consultations with stakeholders in circumstances where federal institutions may reject community priorities.

These first two proposals relate specifically to subsections 41(9) and 41(9.1) of the act and stem from the observation that sections 5 and 6 of the draft regulations lack precision with regard to the obligations of federal institutions in the dialogue and consultation processes.

There have been a lot of suggestions put forward to define what constitutes effective consultation. We can come back to that if you like.

The regulations must ensure that impact indicators are based on evidence-based findings and that the data accessible to the public, particularly the research community, is used to assess progress towards achieving the objectives through the positive measures implemented, and to impose a review of these measures if they do not meet the objectives set.

Subsections 41(8) and 41(9) of the bill read as follows:

(8) The analyses […] shall be founded, to the extent possible, on the results of dialogue and consultation activities, on research and on evidence-based findings. (9) […] permit the priorities of the English and French linguistic minority communities and other stakeholders to be taken into account…

However, nothing in the regulations defines or regulates the production or dissemination of such findings.

Given that the new version of part VII now explicitly names in subparagraph 41(6)(c)(v) sectors of application of positive measures that fall within provincial or shared jurisdiction as “sectors that are essential to enhancing the vitality of […] minority communities” and refers to the need to “protect and promote the presence of strong institutions serving those communities”, the regulations must be much more explicit with regard to the federal government's obligations towards minorities in each province and territory. This applies to consultation, consideration of priorities and the role that communities and their institutions play in implementing federal-provincial-territorial agreements on official languages.

Moreover, the Federal Court's decision last December in the case of Conseil scolaire francophone provincial de Terre-Neuve-et-Labrador v. Canadian Heritage lends weight to this argument by finding Canadian Heritage guilty of failing to fulfill its obligations to consult with the community under the previous version of the Official Languages Act. However, both the intention of the legislator and the new text of the act itself clearly demonstrate a desire to strengthen these obligations. The regulations should also dictate to the federal government its course of action in circumstances where a province or territory refuses to co-operate in any of the sectors essential to enhancing the vitality of minorities.

Finally, again with regard to subparagraph 41(6)(c)(v), the regulations should set out the criteria that will be considered to define what the act means by “strong institutions”. Here, before I'm told that regulations cannot provide a definition that was not present in the act, I'd like to point out that the official languages (communications with and services to the public) regulations, or the part IV regulations, provide an example of such a practice. In part I of those regulations—

[The Chair, Liberal, Yvan Baker]

Ms. Chouinard, I'm sorry to interrupt you. Please wrap up your presentation, because your time is up.

[Stéphanie Chouinard]

Okay.

The regulations include a set of criteria designed to determine whether a given region faces significant demand for services in the official language of the minority. So there's a way to codify terminology in the regulations. It remains possible to do so without including a definition per se. I would like to see the same approach used on the “strong institutions” issue in the part VII regulations.

Therefore, many regulatory changes are needed, in my opinion, to implement—

[The Chair, Liberal, Yvan Baker]

Ms. Chouinard, I really must interrupt you. The time is up.

We'll now go to questions from members. I'm going to turn the floor over to Mr. Godin for six minutes.

[Joël Godin, Conservative, Portneuf—Jacques-Cartier, QC]

Thank you, Mr. Chair.

I'd like to thank the representatives of Canadian Parents for French, Mr. Visweswaran and Mr. Bentley, as well as Ms. Chouinard and all the other witnesses who delivered opening remarks.

My first question is for the representatives of Canadian Parents for French.

You talked about defining “other stakeholders”.

In your opinion, what would be the best definition, or the definition that would include you so that you are considered one of the major players in the process?

What definition would you like to see in the regulations?

[Ahdithya Rajan P. Visweswaran, Director, Advocacy and Public Policy, Canadian Parents for French]

Thank you for the question.

Here's the exact wording we'd like to see: “…stakeholders who are actively engaged in advancing the commitments under subsections 41(1) and 41(3) of the act."

[Joël Godin, Conservative, Portneuf—Jacques-Cartier, QC]

If we made this change to the regulations, you would therefore consider yourself included in the definition. That way, you would be part of the consultation process.

Is that correct?

[Ahdithya Rajan P. Visweswaran]

Yes, that's right.

[Joël Godin, Conservative, Portneuf—Jacques-Cartier, QC]

Let's talk about consultation. According to a representative of Droits collectifs Québec who spoke earlier, it took a long time to draft the regulations. So there were probably a lot of consultations.

Was your organization consulted on the drafting of these regulations?

[Ahdithya Rajan P. Visweswaran]

Yes. We were consulted a number of times in the pre-consultation phase. However, none of what we expressed, including our concerns about “other stakeholders”, was taken into account.

[Joël Godin, Conservative, Portneuf—Jacques-Cartier, QC]

Don't worry. Don't feel singled out, because you're not alone.

Thank you for that.

I will now turn to the representatives of Droits collectifs Québec.

I understand from your remarks that you're disappointed.

It's all well and good to say that you're not happy. We recognize that it has taken too long, and we share your opinion. Urgent action is needed because French is in decline. However, it took two and a half years to draft the regulations. Everyone, or at least the majority of those who have appeared before us, told us that the regulations didn't meet the objectives set and that we had to go back to the drawing board.

Can you give us some solutions?

[François Côté]

Yes, we can do that.

Two of them are particularly interesting.

First, the objectives need to be clearly stated. For example, the regulations need to specify demographic measures, such as the percentage of speakers in the provinces, including Quebec. We have to be able to see the progress of official language minority communities, the progress of French in the provinces and in Quebec, and so on.

Clear objectives to achieve must be set, such as monetary targets or budgets. The regulations need to talk about language transfer. In short, we need concrete, measurable objectives. That's sorely lacking in these draft regulations. In their current form, these draft regulations can essentially mean anything and everything.

The analytical methodology also needs to be clarified. For the time being, in extremely vague terms, we're only talking about analyzing the impact or establishing potential positive measures. Those are terms that leave way too much room for creativity to be truly effective. We have to talk about a specific sample to be measured and targets, particularly financial ones, to be achieved. We need to say more clearly who the stakeholders are and specify the areas where action is needed.

The draft regulations need to be clear, and right now they're not.

[Joël Godin, Conservative, Portneuf—Jacques-Cartier, QC]

Thank you.

I will now turn to the other witnesses.

Ms. Chouinard, I think you will agree with what we just heard from the previous witness. Clarity and measurability were mentioned.

That's all well and good, but how can we do that?

On this side of the table, what we want is to have the regulations make it possible to achieve the objectives.

In concrete terms, what can we put in the regulations to leave no room for interpretation or loopholes so that the objectives can really be achieved?

[Stéphanie Chouinard]

Thank you, Mr. Godin.

I won't be telling you anything new when I say that the purpose of the Official Languages Act is to have a certain transversality. This means that the act is applied horizontally, which involves all agencies and departments. The objectives will therefore differ from one agency or department to another, but there must be an obligation to establish those objectives and there must be effective consultation.

The regulations should set out what an effective consultation is so that we can then say that the consultation actually took place.

The Office of the Commissioner of Official Languages has set out very specific criteria for what constitutes effective consultation. The Fédération des communautés francophones et acadienne du Canada has also done so.

I won't repeat them here, but these are things we should see in the regulations to be able to say, following such consultation, that the agencies and departments have done their job. Objectives have to be measurable and we have to know where to get the evidence to measure how well they have been met.

[Joël Godin, Conservative, Portneuf—Jacques-Cartier, QC]

I would like to ask you more questions, Ms. Chouinard, but the chair is telling me that my time is up.

Thank you.

[The Chair, Liberal, Yvan Baker]

I'm sorry, Mr. Godin.

Ms. Mingarelli, you have the floor for six minutes.

[Giovanna Mingarelli, Liberal, Prescott—Russell—Cumberland, ON]

Thank you to all the witnesses for being with us today.

Ms. Chouinard, you recommend that the regulations include clear and measurable objectives.

What would an objective consistent with part VII look like?

Can you give an example of the kind of inconsistent objective you see all too often?

[Stéphanie Chouinard]

Thank you for the question.

As I said to Mr. Godin, I don't think those specific objectives need to be in the regulations. However, each federal agency and department must be required to have and clearly state these objectives. They must be known to the public, and they must be measurable using evidence-based data. Small and large-scale objectives may look different. In a small organization like mine, the Royal Military College of Canada, it could be the number of students who have access to their entire program in the official language of their choice. On a larger scale, we could look at whether there is linguistic parity among officers and soldiers in the Canadian Armed Forces.

However, we cannot expect such objectives to be in the regulations for all 192 departments and agencies. That's not what the regulations are for. The regulations should ensure that each agency and department has done its job and consulted stakeholders in developing these objectives. The regulations must also ensure that these organizations tell us how they are going to gather data to determine whether they've met their objectives and, if they haven't met them, what measures will be taken to correct the situation.

[Giovanna Mingarelli, Liberal, Prescott—Russell—Cumberland, ON]

Thank you very much.

Now I have some questions for the Canadian Parents for French representatives.

What barriers to access are you still seeing, such as waiting lists, selection criteria, school transportation, hidden fees or lack of information?

Should the regulations require equitable access plans for each region that include targets and timelines?

[Derrek Bentley]

Thank you for the question. That's a big question.

Education falls within provincial and territorial jurisdiction. That complicates things. In some regions, there are still waiting lists for immersion programs. At midnight, parents go to school and line up to secure a spot for their children.

Canada often presents itself, nationally and internationally, as a bilingual country where people can live fully in French just about everywhere, but there are still challenges related to access and waiting lists. Some kids have access to a school, but others don't. Parents have to make tough decisions. It's sad that we're still at this point.

As far as the regulations are concerned, I would agree with Ms. Chouinard. I don't think the government can put specific targets in the regulations. However, the regulations should require organizations to set linguistic duality and bilingualism objectives.

For example, if a department's objective is for 25% of Canadians outside Quebec to be bilingual, it must implement positive measures to achieve that objective, such as making changes to education. It must also consider a whole-of-government approach to increasing the number of bilingual Canadians.