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Special thanks to our articling student Rana Aly for contributing to this update.

Quebec’s multi‑year modernization of its occupational health and safety (OHS) system reached full implementation in late 2025. There are permanent prevention and participation mechanisms under the Act to Modernize the Occupational Health and Safety Regime (AMOHSR) and its accompanying regulation (Regulation Respecting Prevention and Participation Mechanisms in an Establishment) now in force. This represents a significant shift in Quebec occupational health and safety law.

Employers must now comply with the new requirements, if they have not already done so.

Below is an overview of the new requirements Quebec employers must be aware of:

1. Foundational Changes to Quebec’s Prevention Framework

The OHS overhaul stems from major reforms introduced by Bill 59 in 2021, with staggered implementation over several years. The permanent regime, effective October 1, 2025, replaces temporary interim mechanisms that applied during the transition period.

Key features of the new framework include:

  • A shift to mandatory prevention planning, scaled by workforce size;
  • Stronger worker participation structures;
  • An expectation of continuous improvement; and
  • New training obligations for worker representatives.

The result is a harmonized and prevention‑first model that applies across industries, regardless of risk profile.

2. Prevention Planning Obligations

Action Plans (Small Workplaces)

Workplaces with fewer than 20 workers must maintain a written action plan that:

  • Identifies workplace hazards (including work‑related psychosocial risks);
  • Sets out measures to eliminate, reduce or control (where elimination or reduction are not feasible) those risks, such as training, maintenance, and supervision;
  • Includes a description of personal protective equipment (PPE);
  • Includes follow‑up steps and timelines; and
  • Is reviewed and updated annually,

Employers were given one year after October 2025 to implement this plan. As of 2026, these plans should already be active with their first update cycle forthcoming.

Prevention Programs (Large Workplaces)

  • Workplaces with 20 or more workers must implement a comprehensive prevention program, which includes all elements of an action plan outlined above, but also emphasizes:
  • Systematic hazard identification;
  • Long‑term risk management strategies; and
  • Ongoing monitoring and periodic reassessment.

Prevention programs must be living documents that reflect operational changes and newly identified risks.

3. Worker Participation and Representation

Health and Safety Liaison Officer (Small Workplaces)

Workplaces with fewer than 20 workers must appoint a health and safety liaison officer, responsible for:

  • Assisting with the preparation and execution of the action plan;
  • Providing written recommendations to the employer; and
  • Completing mandatory Commission des normes, de l’équité, de la santé et de la sécurité du travail (CNESST) training within one year of designation.

For many workplaces, these training deadlines will occur in 2026.

Health and Safety Committee (Large Workplaces)

Where 20 or more workers are employed for at least 21 days per year, employers must establish a health and safety committee (HSC) composed of:

  • At least one worker representative; and
  • At least one employer representative.

The HSC supports the prevention program, reviews incident information, and contributes to ongoing risk monitoring.

Health and Safety Representative (Large Workplaces)

Workers in these larger workplaces must also appoint a health and safety representative (HSR) with defined duties, including:

  • Accompanying an inspector during workplace inspections;
  • Reviewing accident notices;
  • Participating in investigations; and
  • Filing complaints, where necessary.

Both the HSR and HSC members must complete a CNESST‑recognized theoretical training for a minimum duration of one day, within 120 days of appointment.

4. Multi‑Establishment Prevention Options

Employers operating several establishments performing similar activities may implement a unified prevention program.

Eligibility Requirements

An employer may adopt a multi‑establishment approach if:

  • At least two establishments each have 20 or more workers; and
  • The establishments carry out activities of the same nature.

Obligations Under the Consolidated Model

When this approach is chosen, the employer must:

  • Develop a single prevention program covering all grouped establishments;
  • Include smaller establishments (under 20 workers) with similar activities;
  • Create one unified health and safety committee;
  • Designate at least one health and safety representative; and
  • Maintain the consolidated structure for at least three years.

This option helps reduce duplication but still requires location‑specific risk consideration.

5. Timelines, Compliance, and Next Steps for Employers in 2026

By 2026, employers should now have:

  • Finalized and implemented their action plan or prevention program;
  • Established required committees and appointed representatives;
  • Scheduled or completed mandatory CNESST training; and
  • Prepared for the first annual update of their action plan or prevention program.

With the CNESST expected to increase compliance oversight and enforcement in 2026, employers should ensure they are in compliance with the new requirements. Solid record‑keeping, due diligence, and proactive monitoring will be essential as the new regime shifts into full enforcement in 2026 and beyond.

Key Takeaways for Employers

Quebec employers should be aware of these new requirements and implement them as applicable to their workplace. For bespoke implementation advice, or for any needed clarification on the new obligations outlined above, please contact your Baker McKenzie employment lawyer.