Quebec Language Law Compliance — Bill 96 / Bill 101 Roadmap
Quebec Language Law Compliance — Bill 96 / Bill 101
Section titled “Quebec Language Law Compliance — Bill 96 / Bill 101”Context: This note consolidates the legal analysis from a January 2026 conversation (prompted by a student complaint) and outlines what Baseworks needs to do to comply with Quebec language laws going forward. The student’s claim was without merit, but the analysis surfaced legitimate compliance gaps.
Corporate Structure — Current
Section titled “Corporate Structure — Current”| Entity | Jurisdiction | Role |
|---|---|---|
| Baseworks International: 9472 4374 Quebec Inc. | Quebec, Canada (LP) | North American operations, baseworks.com |
| Shaspo, LLC | Estonia | EU operations, practice.baseworks.com |
Both entities are named in the Terms of Service. The Quebec entity triggers Bill 96 obligations for Quebec-facing commercial activity.
What Bill 96 Requires (for a Quebec-incorporated business)
Section titled “What Bill 96 Requires (for a Quebec-incorporated business)”Must comply:
Section titled “Must comply:”- Commercial information and advertising available in French
- Website content (commercial pages) must have French equivalent, accessible independently
- Contracts of adhesion (T&Cs, enrollment terms) must be presented in French first, then parties can choose English
- Employment contracts for Quebec-based staff in French
- Consumer communications (invoices, receipts) in French or bilingual
Does NOT require (adult education / professional development exemption):
Section titled “Does NOT require (adult education / professional development exemption):”- Course content delivered in French
- In-person instruction in French
- Student French proficiency
- Educational materials translated to French
Key exemption: “The Charter of French Language does not apply to Adult Education or Vocational Training programs.” Baseworks is private, non-subsidized, non-degree-granting adult education — stronger exemption than even McGill or Concordia.
Additional factors in Baseworks’ favor:
Section titled “Additional factors in Baseworks’ favor:”- Under 25 Quebec employees (currently 2) — exempt from francization committee requirements
- International student body and hybrid online/in-person model
- English is the standard international language of instruction
- French subtitles already provided for online content (exceeds requirements)
Current Compliance Status
Section titled “Current Compliance Status”| Area | Status | Notes |
|---|---|---|
| Course content language | Compliant | Adult education exemption; English instruction permitted |
| French subtitles for online content | Exceeds requirements | Already provided |
| French landing pages for Quebec events | Partially compliant | Exists for some events, states English instruction |
| Terms of Service in French | Not compliant | English only, hosted via Termageddon |
| Privacy Policy in French | Not compliant | English only |
| Cookie Policy in French | Not compliant | English only |
| EULA in French | Not compliant | English only |
| Disclaimer in French | Not compliant | English only |
| Checkout terms acknowledgment | Compliant | Global WooCommerce checkbox: bilingual EN/FR with links to both policy pages (2026-03-08) |
| Enrollment forms in French | Not compliant | Should present French first, then English option |
| Website language toggle | Not compliant | No sitewide French toggle; French pages exist but not prominently accessible |
| Employment contracts (2 staff) | Unknown | Need to verify if Patrick and Asia’s contracts are in French |
| Invoices/receipts | Unknown | WooCommerce generates these; need to check language settings |
Termageddon Strategy — Decision
Section titled “Termageddon Strategy — Decision”Decision (2026-03-07): Keep Termageddon for English policy generation. Create standalone French policy pages separately.
- Termageddon widgets stay on English policy pages — they auto-update when laws change, which is the core value of keeping the service
- French policy pages are standalone WordPress pages with static translated content — not Termageddon widgets, not WPML
- No third WPML language added (site currently has English + Japanese via WPML; French pages are independent)
- When Termageddon updates an English policy, the corresponding French page needs a manual update — set up change notifications or periodic diff check
- Google Translate notice (as used on the Japanese
/ja/terms-of-service/page) does NOT comply with Bill 96 — the business must provide the French version itself; the consumer cannot be asked to machine-translate - For Termageddon replacement considerations, see Termageddon Replacement Assessment
Action Plan
Section titled “Action Plan”Phase 1 — Immediate compliance (before next Montreal cohort)
Section titled “Phase 1 — Immediate compliance (before next Montreal cohort)”1a. French policy pages (machine-translated)
Section titled “1a. French policy pages (machine-translated)”Create standalone WordPress pages for French versions of all 5 policies:
| English page | French page | Status | WP ID |
|---|---|---|---|
/terms-of-service/ | /conditions-dutilisation/ | Live (2026-03-08) | 48334 |
/privacy-policy/ | /politique-de-confidentialite/ | Live (2026-03-07) | 48335 |
/cookie-policy/ | /politique-de-cookies/ | Live (2026-03-07) | 48341 |
/eula/ | /contrat-de-licence/ | Live (2026-03-07) | 48342 |
/disclaimer/ | /avis-de-non-responsabilite/ | Live (2026-03-07) | 48343 |
- Static content — not Termageddon widget, not WPML
- Machine-translated initial versions (AI-assisted); professional review deferred to Phase 2
- Cross-link at top of each page: English page gets “Version française disponible” link; French page gets “English version available” link
- A machine-translated French version that is 90% accurate demonstrates good-faith compliance effort; having no French version at all is the real risk
- Deployment details: see
baseworks-changelogentry 2026-03-07 20:15
Remaining for Phase 1a:
Create French Terms of Service after Termageddon English update is finalized— Done 2026-03-08, WP ID 48334Add “Version française disponible” cross-links to the 5 English policy pages— Done 2026-03-08, paragraph block added above Termageddon embeds- Review French Privacy Policy content — English was updated on Termageddon Mar 7, 2026; French is based on Sep 22, 2025 version
- Cookie Policy French page updated 2026-03-08 with 4 new functional cookies (Google Fonts, reCAPTCHA, Google AJAX, AWS)
1b. Checkout terms acknowledgment
Section titled “1b. Checkout terms acknowledgment”Before any add-to-cart redirect on Montreal event pages, users must acknowledge French terms via checkbox. No custom WooCommerce plugin needed — modifications to existing custom code at each checkout entry point:
Practice Sessions — intake form (Outcome A card):
- The
[bw_practice_quiz]shortcode (custom PHP, delivered via Fluent Snippets) produces Outcome A with a direct add-to-cart link (/?add-to-cart=47341) - Add a checkbox + French terms link inside the outcome card HTML, before the “Purchase Intro Session Pass” CTA
- CTA button hidden/disabled until checkbox is checked
- Code location:
baseworks-changelog/sites/baseworks.com/code-snippets/2026-03-05-practice-sessions-quiz-v2.php - See Practice Sessions Infrastructure — Known Gaps
Practice Sessions — booking widget (alumni/standard):
- The
baseworks-practice-sessions.phpmu-plugin renders a checkout button for returning participants - Add same checkbox before the checkout button in the widget output
- See Practice Sessions Booking Widget
Study Group — “Join the Program” CTA:
- The study group event page has a direct checkout link (
/?add-to-cart=47539) - Add checkbox above the “Join the Program” button (Elementor page edit or custom shortcode wrapper)
Checkbox text (bilingual):
J’ai lu et j’accepte les conditions générales / I have read and accept the Terms and Conditions
Note — global WooCommerce checkout checkbox (2026-03-08): In addition to the above entry-point-specific checkboxes, the standard WooCommerce “terms and conditions” checkbox at checkout has been made bilingual: *“I have read and agree to the website terms and conditions. / J’ai lu et j’accepte les conditions générales. ” with links to both the English and French policy pages. This applies to all orders sitewide and provides broader coverage than the entry-point checkboxes above.
1c. French practice sessions page
Section titled “1c. French practice sessions page”- Duplicate the practice sessions page as a standalone French WordPress page (not WPML)
- Duplicate the
[bw_practice_quiz]shortcode as a French variant ([bw_practice_quiz_fr]or alang="fr"parameter) with French strings for all 6 steps and outcome cards - French form Outcome A card includes the French terms checkbox natively
- Cross-link between English and French practice sessions pages
- The French intake form is a known gap already tracked in Practice Sessions Infrastructure
- Code reference:
baseworks-changelog/sites/baseworks.com/code-snippets/2026-03-05-practice-sessions-quiz-v2.php
Phase 2 — Professional review and extended compliance
Section titled “Phase 2 — Professional review and extended compliance”- Professional translation review of all French policy pages created in Phase 1
- Quebec lawyer review of French terms and the checkout acknowledgment flow
- WooCommerce invoice/receipt language — verify and configure for Quebec customers
- French order confirmation emails for Quebec-based customers
- Employment contracts — verify Patrick and Asia’s contracts are in French (or bilingual)
- French study group event pages (practice sessions partially addressed in Phase 1c)
Future Consideration — Full French E-Commerce Compliance
Section titled “Future Consideration — Full French E-Commerce Compliance”Added 2026-03-09. Research conducted into whether French policy pages and terms alone constitute full Quebec compliance for the e-commerce store.
Finding: French policies and terms are necessary but likely not sufficient for full Bill 96 compliance. The Charter requires more than translated legal pages for a Quebec-incorporated business selling to Quebec consumers.
What the law technically requires beyond policies/terms:
| Requirement | Current status | Source |
|---|---|---|
| Full French website version (product/service descriptions, all commercial pages) | Not done | Éducaloi; Smart & Biggar |
| French checkout flow (cart, order forms, payment pages) | Not done | Éducaloi — “all information a customer needs to make a purchase” |
| French invoices, receipts, order confirmation emails | Not done (flagged as Phase 2 item 3–4) | Charter s. 55 (consumer communications) |
| French-first presentation of contracts of adhesion (not just bilingual toggle) | Partially done (bilingual checkbox, not French-first flow) | Gowling WLG; Charter s. 55.1 |
| ”Markedly predominant” French in commercial advertising (2x visual space, as of June 1, 2025) | Not assessed for online ads | DLA Piper; Fasken |
Mitigating factors in Baseworks’ favour:
- Adult education / course content exemption remains strong — course delivery, instruction, and educational materials do not need to be in French
- Educational and cultural products (like course content) can be exclusively in English under the Charter
- French policies are live, bilingual checkout checkbox exists, cross-links in place — demonstrates good-faith compliance effort
- Under 25 employees — exempt from francization committee
- OQLF enforcement historically prioritizes larger businesses (though Bill 96 expanded their powers and penalty range up to $140,000)
- Most likely enforcement trigger is a complaint, not a proactive audit
Practical risk assessment:
The gap between current state and full compliance is the commercial wrapper around the educational product: product descriptions, checkout flow, transactional emails. Whether Baseworks’ specific business model (gated adult education, not open retail) provides additional protection beyond the general commercial rules is an open question best resolved by the Quebec lawyer review already planned for Phase 2.
Recommendation: Prioritize the Phase 2 Quebec lawyer review (item 2) to get a definitive answer on whether the adult continuing education model provides sufficient exemption from full e-commerce translation requirements, or whether a French checkout and product pages are needed. Until then, current state represents strong good-faith compliance.
Sources:
- Éducaloi — Language Laws and Doing Business in Quebec
- Gowling WLG — Bill 96’s “French First” Rule
- Smart & Biggar — Quebec’s French Language Requirements
- CFIB — Everything About Quebec’s Law 14
- DLA Piper — Quebec Language Laws Changes 2025
Phase 3 — Long-term positioning
Section titled “Phase 3 — Long-term positioning”- Corporate restructuring decision (not urgent — current compliance gaps are the priority)
- Option A: Keep Quebec entity as primary, comply with Bill 96 for commercial materials (simpler, lower cost)
- Option B: Make Estonia entity primary, Quebec entity limited to local venue/employment (reduces Bill 96 scope but adds corporate complexity)
- Enhanced checkout modal — if Phase 2 legal review determines the checkbox approach is insufficient, develop a full modal plugin with embedded terms, scroll tracking, and order meta logging
- Geo-detection — consider Quebec IP detection to auto-suggest French version of pages
The Student Complaint (Reference Only)
Section titled “The Student Complaint (Reference Only)”A student (January 2026) claimed Baseworks was not complying with Quebec language laws because course content was in English. Analysis concluded:
- Her claim was invalid — adult education content language is exempt
- She had French commercial information — French landing page existed and stated English instruction
- Acceptance by conduct — she purchased and completed a lesson in English
- Bad faith pattern — language was the 5th different reason cited for requesting a refund
- No response was sent — case was closed
However, the analysis did surface that Baseworks has legitimate compliance gaps in commercial/consumer materials (policies, enrollment terms, website toggle) that should be addressed regardless of her claim.
Key Legal References
Section titled “Key Legal References”- Bill 101 (Charter of the French Language) — foundational Quebec language law
- Bill 96 (Law 14, 2022) — modernization of Bill 101, expanded requirements for businesses
- Adult education exemption — CQLR, c. C-11, does not apply to adult/vocational training
- Contracts of adhesion — must present French version first (effective June 1, 2023)
- 25-employee threshold — francization committee not required below this
Related
Section titled “Related”- Terms of Service (vault copy)
- Privacy Policy (vault copy)
- Termageddon Replacement Assessment
- Practice Sessions T&Cs Addendum
- Practice Sessions Infrastructure — intake form and booking widget technical docs
- Practice Sessions Page Draft + Intake Form — page copy and form strategy
- Practice Sessions Booking Widget — alumni/standard checkout widget