Bill 64 (Law 25): What Ontario Businesses Targeting Quebec Must Know

When Quebec passed Bill 64 (now known officially as Law 25), it fundamentally altered the data privacy landscape in Canada. Bringing in strict, GDPR-style requirements and massive potential fines for non-compliance, the law went into effect in progressive phases between 2022 and 2024. Today, in 2026, enforcement is in full swing.

But if your business is based in Toronto, Ottawa, or anywhere else in Ontario, you might wonder: "Why should we care about a Quebec provincial law?"

The answer lies in the extraterritorial reach of Law 25. The law does not care where your corporate headquarters is located. It cares about whose data you are collecting.

If your Ontario-based business has customers, clients, users, or subscribers residing in Quebec, you are legally obligated to comply with Law 25. Failing to do so can result in staggering administrative penalties—up to $25 million CAD or 4% of your global turnover, whichever is greater.

This compliance guide breaks down what Law 25 expects of your business, how it compares to PIPEDA, and the steps you must take to protect your business.

Law 25 vs. PIPEDA: The Major Shifts in Compliance

While Ontario businesses are likely familiar with Canada's federal privacy law, PIPEDA, Law 25 is significantly more aggressive, structured, and punitive. If you only align your systems with standard PIPEDA practices, you have severe compliance gaps under Quebec law.

Three major shifts set Law 25 apart:

1. Mandatory Privacy Officers by Default

Under PIPEDA, businesses are expected to appoint an accountable Privacy Officer. Under Law 25, the person with the highest authority in the company (typically the CEO, President, or Owner) is automatically designated as the Privacy Officer by default.

While the CEO can delegate this role in writing to an external or internal specialist, the ultimate legal responsibility and personal liability remain tied to the highest office.

2. High-Stakes Financial Penalties

PIPEDA is historically a complaint-driven, cooperative law. While the Federal Court can impose penalties, the process is long.

Law 25, on the other hand, introduces direct Administrative Monetary Penalties (AMPs). The Commission d'accès à l'information (CAI), Quebec's privacy regulator, has the power to issue immediate, heavy fines without going through a prolonged court process. For minor small businesses, these fines can easily run into tens of thousands of dollars, while major violations scale up to $25 million CAD.

3. Strict Consent and the "Right to Be Forgotten"

Consent under Law 25 must be explicit, free, informed, and given for a specific purpose. Pre-checked opt-in boxes or hidden terms are completely illegal. Furthermore, Law 25 introduces the Right to Portability and the Right to De-indexation (the "Right to Be Forgotten"). Residing Quebec citizens can legally demand that your business completely erase their profile from your databases, search engines, and partner platforms.

Core Obligations for Ontario SMBs Under Law 25

If you collect personal information from individuals in Quebec (even if it's just email addresses for an e-commerce order or corporate client files), you must fulfill the following operational requirements:

A. Establish a Privacy Incident Log

Law 25 mandates that all organizations, regardless of size, maintain a comprehensive internal Privacy Incident Register. In the event of a data leak, unauthorized access, or database exposure, your business must:

• Immediately take measures to reduce the risk of harm to affected individuals.
• Log the exact details of the incident in your register.
• If the incident presents a "risk of serious injury," you must immediately report the breach to both the CAI and the affected individuals.

B. Conduct Privacy Impact Assessments (PIAs)

Before your business transfers any personal data of Quebec residents outside of Quebec (which includes storing client data on Ontario cloud servers, Vercel hosting, or using US-based services like Mailgun or Microsoft 365), you must perform a formal Privacy Impact Assessment (PIA).

The PIA must evaluate if the receiving jurisdiction offers "adequate protection" for personal data and establish specific contract terms that guarantee data security.

C. Provide an "Opt-Out" Mechanism for Profiling Technology

If your website utilizes tracking pixels, cookies, or profiling technologies (such as Meta pixel, Google Analytics, or marketing tracking scripts) that identify, profile, or locate a user, you must:

• Inform visitors at the time of entry that you utilize these tools.
• Provide a clear, simple mechanism to turn these tracking tools off immediately (an "Opt-Out" toggle).
• Ensure that these cookies are blocked by default until the user explicitly consents.

How to Prepare Your Business for Cross-Provincial Compliance

Aligning your Ontario operations with both PIPEDA and Quebec's Law 25 requires a systematic audit of your internal infrastructure:

1. Perform a Data Localization Audit: Map out where your customer data is stored. If you store data on-premise, in the cloud, or share it with third-party software vendors, ensure you have formal data transfer agreements and robust security safeguards.
2. Draft a Privacy Incident Plan: Prepare a step-by-step checklist for your team to follow in the event of a breach. Who logs the incident? How do you measure "risk of serious injury"? Having a templated plan prevents costly compliance delays.
3. Deploy a Consent Management Platform (CMP): Ensure your website features a professional cookie consent banner that blocks tracking scripts by default for Quebec visitors and offers clear opt-in and opt-out paths.
4. Partner with Compliance Specialists: Evaluating cross-provincial requirements requires experienced, objective analysis to ensure you don't over-invest in redundant software or overlook critical vulnerabilities.

Secure Your Enterprise Compliance Footprint

Navigating multi-provincial privacy laws can be complex and expensive for growing Ontario firms. You need a partner who can evaluate your complete technical and administrative posture, rather than just selling you a templated PDF.

At CanadaSecure, our Enterprise Security Assessment Package is designed specifically for high-growth firms and regulated industries facing complex compliance requirements. We perform a deep-dive configuration review of your cloud infrastructure, build incident response templates, evaluate your vendor supply chain, and provide a comprehensive compliance map to satisfy Law 25, PIPEDA, and provincial guidelines. Secure your data, reduce your liability, and build bulletproof client trust.