Law 14 (previously known as Bill 96) in Quebec

On June 1, 2022, the Quebec Government passed new legislation – called An Act Respecting French, the Official and Common Language of Quebec (Law 14, previously known as Bill 96). Law 14 seeks to protect and promote French as the official language in Quebec through amendments to several pieces of existing legislation, mainly the Charter of the French Language (the Charter). 

To ensure you stay compliant with Law 14 in Quebec, we’ve put together the following guidelines for products and processes for doing business with Clients residing in Quebec. These new processes are required as of June 1, 2023.

Please note, these changes only impact Clients in Quebec whose preferred language is English. If the Client is based in Quebec and their preferred language is French, there are no changes to existing processes. 

All life insurance or health insurance products

  • If the Client(s) reside(s) in Quebec, and
  • The Client’s preferred language is English:
    • You are required to provide a blank copy of the French application to the Client prior to completing the English version
      • Note: Starting November, 2023, any new policy will be sent to the Client in French and English. A separate policy booklet will be printed and mailed in each language.
    • Once the policy is in-force, any communications sent to the Client will be in their language of preference.

FAQ

Using this document

This document is intended to provide a summary of how Law 14 (previously Bill 96 amending the Quebec Charter of the French Language) changes the way Sun Life does business and communicates with Quebec Clients whose preferred language is English as well as other contracting parties.

These changes do not impact the way Sun Life currently serves Quebec Clients whose preferred language is French. We should always provide service to these Clients in French.

Starting June 1, the Quebec Charter of the French Language requires the French version of Sun Life contracts be provided first to Clients in Quebec.  Upon receipt of the French version, a Client in Quebec whose preferred language is English may then ask to receive the English version of the contract as well as all related documents to the contract in English. 

Frequently asked questions

A: Law 14 applies to all insurance and investment contracts, including applications and contractual documents for life insurance, health insurance, annuities, segregated funds, mutual funds and GICs. 

These contracts must be issued/provided to Clients in Quebec in French. An English version of the contract can be made available to Clients in Quebec upon request but only after, or at the same time, they receive the French version.

A: No.  Law 14 applies only within the Province of Quebec. 

A: Yes, in Quebec, the application is an integral part of the contract.  The French version of a blank application must be provided to the Client even if their preferred language is English, before completing the English version with the Client. If the Client’s preferred language is English, only the English application needs to be filled out and submitted to Sun Life. The policy/contract will also have to be provided in French, even if the application is filled out in English. However, they can also be provided the English version of the policy/contract. 

A:  No. As of June 1, 2023, this is no longer allowed.  However, only one version needs to be completed by the Client.

A:  A Client would be entitled to invoke the nullity of the contract and ask for the return of premiums plus damages. Sun Life could also face regulatory penalties.

A:  Yes. If a Client has expressed English as their language of preference, once they receive their contract (application and policy/contract) in French, Law 14 states that all related documents can then be sent to the Client in English only.  Related documents mean any communication with the Client and forms allowing the Client to exercise their rights under the policy/contract.

For example, this would apply to the Client’s right to change a beneficiary designation, to add a contingent beneficiary or policyholder, to assign their policy as collateral security, to surrender the policy or cancel the policy/contract. A related document would also include a notice to change premiums.

A:  Yes, for Clients who requested to receive these documents in English. The French version of the application must be provided to the Client before they can complete the English version of the application. The policy/contract will also have to be provided in French to Clients who reside in Quebec even if the application is filled out in English.

A: No. The original English policy/contract is still valid.

A:  No, advisors can keep records in their language of preference.

A:  Yes, examples of third parties are:  authorized individuals such as a power of attorney (POA or mandatary), tutor, assistant, or external organizations (e.g., when handling the transfer of funds). When communicating with these individuals, Sun Life will do so according to the Client’s language of preference except if the third party writes to Sun Life in another language or specifically asks to receive communications in another language. 

A: Sun Life could be subject to the following fines:

  • First offence* $3,000 to $30,000
  • Second offence $6,000 to $60,000
  • Subsequent offences $9,000 to $90,000