Thank you very much.
I will refrain from commenting on the technical aspects.
Let us now turn to the point I wanted to make.
The draft regulations truly constitute an infringement on Quebec's political and legal jurisdiction regarding the French language. Remember, while the draft regulations may have positive impacts outside Quebec, they disregard Quebec's jurisdiction and the authority granted to the province by the Charter of the French Language, which has already been fully applicable to federally regulated private businesses since 1977 following the adoption of the Charter of the French Language and explicitly and clearly under Bill 96, which explicitly states that the charter applies to federally regulated businesses.
The draft regulations do not fill any legal vacuum in Quebec. They create a legal problem for the sake of petty constitutional politics and to establish a language monitoring regime that is less effective than that provided for by the Charter of the French Language.
Quebec has 370 federally regulated private businesses with 50 or more employees, according to 2025 figures from the Office québécois de la langue française, or OQLF. Of these, more than 350 are properly registered and comply with the OQLF's francization requirements. Only 12 of them are non-compliant. We must therefore not see a problem where none exists. The regime proposed by the draft regulations would apply only to private businesses with 100 or more employees, thereby depriving workers in businesses with 25 to 99 employees of all their language rights in one fell swoop.
We also take issue with the fact that enforcement of the draft regulations will be entrusted to the Office of the Commissioner of Official Languages of Canada, a highly respectable institution, but one with no experience in supporting private businesses. The Commissioner of Official Languages oversees the public sector.
However, the OQLF has 49 years of expertise in supporting private businesses. This expertise would be sidelined in favour of a regime that provides for neither monetary penalties nor the power to issue orders, whereas the OQLF does. The regime does not provide for the power to investigate proprio motu, that is, on its own initiative, whereas the OQLF holds such power. We would therefore have to wait for a complaint to be filed, rather than monitoring situations of concern. Unfortunately, in businesses, complaints are simply suppressed, often due to pressure and the habit of switching to English. There is no corrective action because no one dares complain.
Finally, the draft regulations also raise the entire issue of the opt-in or opt-out clause. The current provision is the default application of the draft regulations, unless a business requests an exemption and to be subject to the Charter of the French Language regime. The regulations are, on the surface, intended to respect Quebec's constitutional jurisdiction, but I see that as a smokescreen. Indeed, how many businesses will choose to be exempted from its application? I doubt there will be many.
The draft regulations thus create a legal problem where none existed and prevent Quebec from exercising its own jurisdiction in accordance with the impairment doctrine recognized since the Canadian Western Bank decision. I see this as an attempt by the federal government to encroach on Quebec's language-related jurisdiction. Our official recommendation is to remove Quebec from the scope of the regime set out in the draft regulations, or, at the very least, make it an opt-in regime.