Quebec Bill 96 and French-first retention messaging for Montreal brands

What to take away

What Quebec's Charter of the French Language requires of commercial messaging

The Charter of the French Language is Quebec's language law, and since Bill 96 amended it, its reach into commercial messaging is wider and better enforced. If you sell to consumers in Montreal, Quebec City or anywhere in the province, your retention emails, SMS and loyalty communications are commercial messages.

The law expects French to be the default, not a courtesy.

The core rule is prominence. French must be markedly predominant in a commercial message, or at minimum available on terms that are at least as favourable as another language. In practice, that means a French version of the same offer, the same deadline and the same call to action, not a French line above an English body.

Bill 96 commercial messaging also changed how businesses register and operate in the province, and the size threshold is now 25 people (see the dates and obligations below). For retention teams, the practical effect is simple: the language of your customer database and your campaign templates is now a compliance question, not a brand preference.

What Bill 96 changed, and when

Bill 96 is the bill behind the Act respecting French, the official and common language of Québec. The Quebec government states that this Act, adopted on 1 June 2022, amended the Charter of the French Language and made French the only official and common language of Quebec.

The authority that applies the Charter to businesses is the Office québécois de la langue française (OQLF). Its obligations page for businesses sets out what retention teams need to know:

For a retention programme, the first and last dates matter most: loyalty terms are usually standard-form terms, and a programme name registered as an English trademark should be checked against the trademark display rules. Consumers can file a complaint with the OQLF, which is why a single English-only birthday email can become a file.

Consumer protection, privacy and tax alongside the language law

Quebec's Consumer Protection Act sits alongside the language rules. A promotional claim in French must be as accurate as the English one, because the same deceptive marketing prohibitions apply. The Competition Bureau Canada enforces those nationally, and a badly translated offer can create a misleading impression just as easily as a false one.

One more layer: consent and sender identity. Canada's Anti-Spam Legislation applies to every retention message you send into Quebec, regardless of language, and personal information sits under privacy law: the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and Quebec's own Act respecting the protection of personal information in the private sector, which Law 25 amended. The Office of the Privacy Commissioner of Canada publishes guidance for businesses on consent and marketing.

Read it before you rebuild a template. The Commissioner also maintains French-language privacy topics that help when you write your own French consent wording.

Retention emails and SMS: where French-first stops being optional

Retention emails are where most brands first feel the law. A win-back series, a replenishment reminder or a loyalty tier update is a commercial message. If the French version is a machine translation bolted on after the English was approved, you have a problem the moment a customer complains.

SMS is stricter in practice because of space. A 160-character French message rarely fits the English copy, so the French version must be written first and the English adapted from it. That reverses the usual workflow for many Montreal brands and is the single change that removes most risk.

Subject lines count. A French subject line with an English preheader is a mixed message, and mixed messages are exactly what the prominence rule targets. Write both in French, then decide whether an English version is needed at all.

Segmentation matters. If you hold language preference data, use it, but do not treat an English preference as permission to skip the French version. The law protects the consumer's right to be served in French, and a preference field is not a waiver.

Our notes on loyalty points vs cashback ecommerce retention cover how to build those preference fields without breaking consent records.

Frequency and timing are not language issues, but they affect retention. A French-first programme that sends less often and reads better usually outperforms a bilingual blast. The principle that a post-purchase email sequence for ecommerce retention earns attention holds in both languages.

For SMS specifically, keep the sender identity in French where the brand has a French name, and keep the unsubscribe instruction in French. Short codes and keywords should be recognisable to a French-speaking customer, not an English word translated at the last minute.

Loyalty programmes, points statements and French-language terms

A loyalty programme is a contract with the customer, and in Quebec the contract has language terms. The programme name, the tier names, the points statement and the redemption rules all fall inside commercial messaging when they are delivered by email or SMS.

Montreal loyalty programme French requirements are often missed at the naming stage. An English programme name with a French subtitle is weaker than a French name with an English translation. If the programme name is a trademark, check how it is registered and how it appears in your Quebec-facing materials.

Points statements are the highest-risk document because they combine a balance, an expiry date and a legal term. A French statement that says the points expire on a different date than the English one is a consumer protection problem, not just a translation problem. Keep one source of truth for the data and render it in French first.

Expiry and forfeiture language deserves a lawyer's eye. Quebec rules on gift cards and prepaid balances have their own history, and loyalty points are not identical to gift cards, so do not copy English terms from another province. Write the French terms, then have them reviewed.

Redemption confirmations, birthday rewards and tier downgrade notices are all commercial messages. Each needs a French version on equal terms. A birthday reward that arrives in English because the automation was built in a US platform is a common failure, and it is fixable in the template layer.

Quebec City ecommerce compliance looks the same as Montreal on paper, but the customer base is more French-dominant. Brands that test French-first in Quebec City often find higher engagement, which makes the compliance work easier to justify internally.

If you run social campaigns alongside email, the canadian ecommerce sms retention tools you choose should be able to produce French creative, not just translate it.

Where translation stops being enough for Montreal and Quebec City merchants

Translation fails when the message is still built in English. The structure, the humour, the urgency and the offer logic carry language. A literal French rendering of an English campaign reads like a translation, and customers notice.

Prominence is a design question as much as a copy question. If the French block is smaller, greyer or lower than the English block, you have not met the standard. Equal prominence means equal size, equal position and equal clarity.

Legal terms are the second failure point. Terms and conditions, privacy notices and contest rules need French versions that a Quebec court would accept. A French summary with an English legal text is not a French version. The Commissioner's guidance covers consent wording you can adapt, and the French pages help you keep terminology consistent.

Customer service is the third. A French retention email that invites a reply in English breaks the promise. Route French replies to French-speaking agents, and route SMS replies the same way. Retention is a conversation, and the language of the reply is part of the message.

Finally, tax and pricing language. Subscription prices shown to Quebec customers include GST and QST, and the way you describe those taxes in French should match the way they appear on the invoice. Revenu Québec, which administers the QST, is the reference point for how those amounts are presented.

Bill 96 French retention messaging Quebec compliance steps

A worked example helps. A Montreal skincare brand sends a win-back email in English with a French paragraph at the bottom. The French paragraph is smaller and omits the discount code. Under the prominence rule, that fails.

The fix is one French email with the code, the deadline and the same design weight, plus an English version for customers who chose English. The French version goes out first, and the English is adapted from it.

Use a checklist before each campaign:

The ecommerce retention marketing fundamentals are the same in Quebec, but the language layer sits on top of them and cannot be deferred.

Working with the Quebec Enterprise Number and register when verifying brand entities

The Quebec Enterprise Number, usually shortened to NEQ, is the identifier the province assigns to a registered business. It appears in the enterprise register and is used for compliance and administrative purposes, including the language obligations that attach to a registered entity.

If your brand operates in Quebec through a subsidiary or a numbered company, you need the NEQ to hand when you file or respond to a request.

Verifying the entity behind a brand matters for retention because consent records and commercial messages attach to a legal person. If you buy a list, inherit a loyalty database or take over a Montreal brand's email programme, check who the registered entity is before you send.

You can find an enterprise by name and confirm the legal identity, which is the first step in any due diligence.

A quick verification routine:

This matters most in acquisitions and agency transitions. A retention programme that was built by an agency under one entity and is now operated by another can leave consent and language obligations unclear. The register resolves the identity question quickly, and it is public.

For subscription and loyalty revenue, the tax side is separate but related. GST and QST treatment affects how you present prices in French retention messages, and Revenu Québec is the place to confirm the QST rate and the rules.

Getting the language right while getting the tax line wrong is still a bad customer experience. If you are weighing platform choices, our ecommerce email marketing notes cover signal versus noise in the tooling decision.

Common questions