Quebec Law 25: data portability effective Sept 22, 2024; penalties up to C$25M / 4% of worldwide turnover

Claim: Quebec Law 25 right to data portability became effective September 22, 2024. The Quebec government recommends CSV / XML / JSON as portable formats and advises against PDFs, images, or proprietary formats.

Penalties:

  • Administrative monetary penalties: up to C$10M or 2% of worldwide turnover (whichever is greater)
  • Penal fines: up to C$25M or 4% of worldwide turnover

Sources: Osler privacy guide 2024; Alation Law 25 overview; BLG legal analysis.

Confidence: Verified.

Implication for Candid clients in Quebec: A Quebec SMB has stronger portability rights than an Ontario SMB does — until federal Bill C-15 (see Canadian Bill C-15 (tabled Nov 4, 2025) — proposes data-mobility framework for federal PIPEDA) catches up. Worth knowing for any client with QC customers or operations.