Since December 17, 2025, a Quebec business that employs 25 or more people must prove that it is complying with the francization process under the Charter of the French Language before Quebec will approve its side of a Labour Market Impact Assessment (LMIA) or validate a permanent job offer. If the proof is missing, or if the company appears on the Office québécois de la langue française (OQLF) list of non-compliant businesses, the application is refused. For many employers, French-language compliance has become a gatekeeping condition for hiring foreign workers at all.
Key Takeaways
- The rule applies to businesses with 25 or more employees in Quebec that are subject to the OQLF francization process. Registered farm operations are exempt.
- It covers both the Quebec LMIA assessment (temporary workers) and the validated job offer used for permanent selection.
- One of four OQLF documents must be attached in the Arrima employer portal, and two of them expire quickly: a registration attestation must be under 3 months old and a linguistic analysis acknowledgement under 12 months old.
- A company on the OQLF non-compliant list cannot obtain a positive LMIA or a validated job offer from Quebec.
- Employers also commit, in the Quebec LMIA form, to tell their temporary foreign workers about free French courses.
Why French compliance now affects hiring foreign workers
In Quebec, an LMIA is assessed jointly: Employment and Social Development Canada (ESDC) reviews the federal criteria, and the Quebec immigration ministry (MIFI) runs its own assessment, which Quebec calls the EIMT auprès du gouvernement du Québec. Quebec added a new condition to its side of that assessment.
According to the Quebec government, a business that operates in Quebec and employs 25 or more people over a six-month period falls under Chapter V of Title II of the Charter, “The francization of enterprises”. Those businesses must register with the OQLF and start a francization process. Section 152.1 of the Charter already barred non-compliant businesses from government contracts and subsidies. Since December 17, 2025, the same compliance is also checked when the business asks Quebec to approve a foreign hire.
At the CBA Immigration Law Conference in May 2026, a panel of Quebec practitioners put it bluntly: without the proof there is no positive LMIA, and in practice that ends the foreign worker hiring plan for that position. The panel’s summary was that immigration eligibility is now tied directly to francization compliance.
Which employers are covered
The requirement applies to every business with 25 or more employees in Quebec that must follow the OQLF francization process. Quebec lists these exclusions:
- businesses registered as agricultural operations under the Quebec farm registration regulation (chapter M-14, r. 1.1);
- businesses with 24 or fewer employees;
- certain organizations that are not subject to the process, such as university institutions, religious associations, professional orders, and businesses located on a First Nations reserve;
- bodies of the civil administration, which are not treated as businesses.
Note the size test. The count is employees in Quebec, not worldwide. A national company with a small Quebec office may fall below the threshold, while a mid-sized Quebec manufacturer will almost certainly be caught. If you are close to 25, confirm your count before you file.
What proof Quebec accepts
The business must attach one of these documents, depending on how far it has progressed with the OQLF:
- Attestation of registration (attestation d’inscription), issued less than 3 months ago.
- Acknowledgement of receipt of the linguistic situation analysis (accusé de réception de l’analyse de la situation linguistique), dated less than 12 months ago.
- Attestation of implementation of a francization program that is in force.
- Francization certificate (certificat de francisation).
If the business has none of these, Quebec says it must contact the OQLF for a letter certifying that it is complying with the francization process.
The document is uploaded in the Arrima employer portal under the document type “Autres” (Other). The same list applies to validated job offer applications for permanent workers.
The expiry trap
The two early-stage documents are time-limited. A registration attestation older than 3 months, or an analysis acknowledgement older than 12 months, will not satisfy the requirement. An employer that registered with the OQLF last year and then stalled may find that its only document has aged out. Check the date on your document before each new LMIA, not just the first one.
The OQLF non-compliant list
Under section 152 of the Charter, the OQLF keeps a public list of businesses for which it has refused to issue an attestation, or whose attestation or certificate it has suspended or cancelled. The OQLF treats those businesses as not complying with the francization process.
Quebec’s position is direct: a business on that list cannot obtain a positive LMIA from Quebec and cannot obtain a validated job offer. It does not matter whether the position is urgent or the candidate is already working in Quebec on another permit.
The CBA panel listed the usual reasons a business ends up on the list: registration never completed, the required linguistic analysis never submitted, a francization program not put in place or not followed, or a certificate or attestation refused, suspended or cancelled. Each of these is a process failure that can usually be seen coming. Assign someone internally to own the OQLF file, and track its deadlines as closely as your LMIA deadlines.
The second new obligation: telling workers about French courses
Since the same date, the Quebec LMIA form includes a commitment that the employer will inform the temporary foreign workers it hires about the francization services available in Quebec. Quebec leaves the method to the employer and says this can happen both before and after the worker arrives.
Quebec gives two examples: encouraging workers to register personally for the free French courses offered by the Quebec government, including courses tailored to fields of work, or setting up workplace courses with support from Francisation Québec and its partners.
Because this is a signed commitment in the application, treat it like any other LMIA undertaking. Keep a record of how and when each worker was informed. Employer compliance reviews look at whether promises made in the application were kept, and the CBA panel noted increased information-sharing between Quebec agencies on employer compliance.
How this fits with other Quebec employer rules
Francization is one of several Quebec-specific conditions that now sit on top of the federal LMIA rules. Employers who place staff at client sites should also check whether they need a CNESST placement agency licence, which we explain in our article on Quebec placement agency licences. Workers already in the Quebec permanent selection queue may be able to use a separate federal public policy, covered in Quebec PSTQ work permit public policy. For the federal side of the LMIA, see our LMIA application to approval guide.
A practical checklist before a Quebec LMIA or job offer validation
- Count your employees in Quebec. At 25 or more, assume the rule applies unless an exclusion fits.
- Find your OQLF file and identify which of the four documents you currently hold.
- Check its date against the 3-month or 12-month limit.
- Search the OQLF non-compliant list for your legal name and any operating names.
- If you hold nothing usable, contact the OQLF for a compliance letter before you start recruitment, since OQLF timelines are outside your control.
- Decide how you will inform workers about French courses and document it.
Frequently asked questions
Does the francization requirement apply to LMIA-exempt work permits?
The Quebec pages describe the requirement at two points: the Quebec LMIA assessment and the validation of a permanent job offer. An LMIA-exempt work permit does not go through the Quebec LMIA assessment, so this specific check is not triggered there. Other Quebec requirements may still apply, and the rule could be extended, so confirm the current position before relying on it.
We have 30 employees but only 10 in Quebec. Are we covered?
The Quebec pages refer to businesses employing 25 or more people in Quebec. If fewer than 25 of your employees are in Quebec, you may fall outside the requirement, but confirm your status with the OQLF, which applies the Charter’s own counting rules.
Our registration attestation is five months old. Can we still use it?
No. Quebec only accepts a registration attestation issued less than 3 months before the application. You would need a more recent document or a compliance letter from the OQLF.
What happens if we are on the non-compliant list?
Quebec will refuse the LMIA assessment and will not validate a job offer. The practical route is to resolve the underlying issue with the OQLF and be removed from the list before applying again.
Does this affect workers already in Canada?
It affects the employer’s application, not the worker’s status directly. But if an LMIA is refused, a worker who needed that LMIA to extend a work permit may lose that route, so plan early. Our LMIA hiring guide covers timing.
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Disclaimer: This article is for general information only and is not legal advice. Immigration law and IRCC/ESDC policy change frequently, and every case turns on its own facts. Reading this article does not create a lawyer–client relationship. Obtain advice tailored to your situation before you act.
Talk to a Canadian immigration lawyer. BridgePoint Law advises individuals and businesses across Canada — and on Canada–US–China cross-border matters — on Quebec employer immigration and LMIA compliance. Book a consultation with our team in Toronto and Kingston. We work in English, Mandarin, and Cantonese.