On April 24, 2025, the Minister of Labour introduced Bill 101, An Act to improve certain labour laws (the Bill), in the National Assembly of Quebec (NAQ). As currently drafted, the Bill proposes a range of amendments – some minor, others more substantive – to key employment-related statutes, including the Labour Code (LC), the Act respecting labour standards (ALS), the Act respecting industrial accidents and occupational diseases (AIAOD) and the Act respecting occupational health and safety (AOHS). It also seeks to defer until 2026 the coming into force of certain provisions of the Act to modernize the occupational health and safety regime (AMOHSR).
Following special consultations held in May and June 2025, the NAQ adopted the principle of the bill on June 5. This endorsement confirmed support for the Bill’s general objectives of the reform and allowed for detailed consideration by a parliamentary committee, expected to take place in fall 2025 when legislative proceedings resume. As the Bill remains under review, amendments are still possible. Nonetheless, the measures currently under consideration could bring significant changes to various aspects of employer-employee relations in Québec.
Below is an overview of the main proposed amendments and their practical implications.
Labour code
With the aim of improving the grievance arbitration process and accelerating its progress, the Bill introduces amendments to the LC to establish mandatory time limits for the appointment of an arbitrator and the scheduling of the first hearing.
An arbitrator must now be appointed within six months of the grievance being filed. If this deadline is not met, the party that filed the grievance will have an additional ten days to request the appointment of an arbitrator by the Minister, failing which the grievance will be deemed withdrawn. The Administrative Labour Tribunal (ALT) may grant a further ten-day extension if circumstances make it impossible to act within the prescribed time.
To prevent grievances from being heard years after they are filed, the Bill also stipulates that the hearing must begin no later than one year after the grievance is filed. At the parties’ request, the arbitrator may grant a single extension for a specific number of days.
The Bill also modifies the rules governing pre-hearing conferences. Currently, such a conference is held at the discretion of the arbitrator. Under the proposed amendments, the arbitrator will be required to hold a pre-hearing conference if either party requests it.
In addition, the Bill provides that any party intending to submit a document or piece of evidence must disclose it to the arbitrator and the other parties within the time limit established during the preparatory conference or, if no such conference is held, at least 30 days before the hearing begins. This measure aims to promote transparency and prevent surprises during the hearing.
The Bill also proposes introducing an obligation for the parties to consider mediation before resorting to arbitration. While this is not a requirement to engage in mediation, the obligation to consider it reflects a broader objective of reducing the number of cases brought before arbitration tribunals and encouraging the resolution of disputes by the parties themselves. It is important to note that the person acting as mediator may not subsequently act as arbitrator in the same case, and that information exchanged during mediation may not be used in arbitration, unless both parties agree.
Act respecting labour standards
The Bill also proposes amendments to the ALS to introduce a new category of protected (unpaid) leave for employees who are unable to perform work because of “a recommendation, order, direction, decision or court order issued under the Public Health Act, the Quarantine Act, the Emergencies Act or the Act respecting civil protection to promote disaster resilience or because of a disaster within the meaning of that latter Act, or its imminence.” Employees wishing to take this leave must notify their employer as soon as possible. Where appropriate, the employer may request the employee to provide documentation supporting the reasons for the absence.
The Bill also amends provisions related to employees who are members of the Canadian Armed Forces Reserve. Specifically, it proposes to reduce the required period of continuous service to qualify for this leave to three months. In the same context, the Bill increases the maximum duration of the leave, extending it to 24 months within a 60-month period.
Act respecting industrial accidents and occupational diseases
The Bill aims to broaden the scope of the exclusive regime under the AIAOD. Specifically, the definition of “worker” would be expanded to include executive officers who personally perform work for a person other than the person for whom they hold the status of executive officer.
In addition, the Bill introduces a new voluntary negotiation process applicable to administrative review applications concerning specific matters. These include a worker’s entitlement to income replacement indemnity, fitness to perform work, access to equivalent or suitable employment, or the determination of what constitutes suitable employment. The AIAOD, as amended, would also establish the rules governing this negotiation process and outline the requirements for any resulting agreement.
Finally, the Bill proposes to amend section 458.1 of the AIAOD. Currently, this provision applies to any employer who attempts to obtain, or obtains, a medical record without authorization. Under the proposed amendment, it would specifically target employers who expressly contravene section 38 of the Act, which prohibits access to a worker’s medical and physical rehabilitation records. The applicable fines would be reduced—except in cases involving medical records related to employment injuries resulting from physical or psychological violence, particularly of a sexual nature. At this preliminary stage, it remains unclear whether the amendment is intended to narrow or broaden the section’s scope, potentially leading to interpretive uncertainty.
Act respecting occupational health and safety
With respect to the AOHS, the Bill introduces a financial support program for employers in cases involving the preventive withdrawal of a pregnant or breast-feeding worker. Specifically, the new provisions would authorize the Commission des normes, de l’équité, de la santé et de la sécurité du travail (CNESST) to reimburse employers when a worker is temporarily reassigned to a position with lower pay than her usual role. This measure is intended to encourage reassignment as a preferred alternative to full withdrawal from work.
Act to modernize the occupational health and safety regime
The Bill also proposes to defer the implementation of certain provisions under the AMOHSR. Under the Act’s original timeline, the interim regime in effect since April 6, 2022, was set to expire on October 6, 2025, giving way to the new AMOHSR requirements. The Bill would amend this timeline by extending the transition period by one year.
As a result, the interim regime would remain in effect until October 6, 2026. After that date, all workplaces with 20 or fewer employees will be required, among other obligations, to implement an action plan. Workplaces with 20 or more employees will be required to adopt a formal prevention program and establish a health and safety committee.
Increase in fines
Finally, the Bill provides for a significant increase in the fines prescribed under the penal provisions of the LC and the ALS.
For example, the fine for breaching the obligation to negotiate in good faith under the LC, currently set between $100 and $1,000 per day, would increase to a range of $1,500 to $7,500 per day. Similarly, the maximum fine for violating provisions related to the use of replacement workers during a labour dispute would rise from $1,000 per day to between $2,500 and $25,000 per day.
Regarding the ARLS, violations of most provisions currently carry fines ranging from CA$600 to CA$1,200 for individuals and CA$1,200 to CA$6,000 for legal entities. The Bill proposes increasing these to CA$1,000 to CA$10,000 for individuals and CA$2,000 to CA$20,000 for legal entities. For certain specific offences—particularly those related to psychological harassment or employment agencies—the fines would increase from CA$600 to CA$6,000 to CA$1,000 to CA$25,000 for individuals, and from CA$1,200 to CA$12,000 to CA$2,000 to $50,000 for legal entities.
Additionally, the Bill provides that fines for repeat offences will be doubled for a second offence and tripled for subsequent offences.
Conclusion
The Bill introduces several amendments that are likely to have a direct impact on human resources management and workplace disputes, particularly in unionized environments. The implementation of new deadlines under the LC, mandatory prior disclosure of evidence, and stricter rules governing mediation and arbitration will require employers to be better prepared well in advance of hearings.
Moreover, the introduction of new protected leaves and the easing of eligibility criteria for certain absences will necessitate updates to internal policies and diligent monitoring of legal obligations. While some measures—such as reimbursement for the temporary reassignment of pregnant or breastfeeding workers—may provide financial relief, they also demand a clear understanding of the new administrative framework.
Finally, the substantial increase in fines for non-compliance underscores the critical need for employers to review and strengthen their internal practices and procedures to ensure full compliance.
We will continue to monitor developments related to this Bill and keep you informed of any changes.
Should you have any questions about the Bill or other issues related to employment and labour, please do not hesitate to contact Arianne Bouchard, Sarah-Émilie Dubois and Daniel Santos Vieira, or any member of Dentons’ Montréal office Employment and Labour group.
The authors would like to thank Simone Lebel, law student, for her contributions to this insight.
