You've heard about Loi 96 and you're wondering whether your invoices need to be in French. If you work with Quebec clients — whether you're based in Montreal or Toronto — the short answer is yes. But the rules are simpler than the headlines suggest, and most freelancers are closer to compliance than they think.
What Is Loi 96?
Loi 96 — officially the Act respecting French, the official and common language of Québec — was adopted on June 1, 2022. It significantly amended the Charter of the French Language (Bill 101), which has governed language use in Quebec since 1977. The goal: make French the default language of work, commerce, and public life in Quebec, with stronger enforcement and broader scope.
Key milestones: most commercial provisions took effect June 1, 2022. New contract requirements (adhesion contracts must be offered in French first) came into force June 1, 2023. Product labeling and francization requirements for 25+ employee businesses took effect June 1, 2025.
Does Loi 96 Apply to Freelancers?
Yes — with one important carve-out. The Charter of the French Language applies to all enterprises doing business in Quebec, regardless of size. Freelancers, consultants, and self-employed workers are not exempt from the commercial document rules.
The part that doesn't apply to you: the francization process. Businesses with 25 or more employees in Quebec must register with the Office québécois de la langue française (OQLF) and complete a formal francization program. As a solo freelancer, you're exempt from this. But the language rules on invoices and commercial documents? Those apply to everyone.
The Invoice Rule: Article 57 of the Charter
Here's the key rule, and it predates Loi 96: Article 57 of the Charter of the French Language requires that invoices, receipts, acquittances, and similar commercial documents be in French. This wasn't invented by Loi 96 — it was already the law. Loi 96 reinforced it and extended its scope.
Practically, this means:
- Invoices to Quebec clients must be in French, or bilingual (French + another language)
- Bilingual invoices are fully compliant, as long as the French version is at least as prominent as any other language
- English-only invoices sent to Quebec clients are not compliant
What About B2B Clients Who Prefer English?
For contracts, Loi 96 allows both parties to agree to use another language — but only after the French version has been offered first. For invoices specifically, the mutual consent exception is less clear-cut. The safest and most practical approach for any Quebec client, B2B or B2C: use a bilingual invoice. French and English side by side, French displayed at least as prominently.
If your B2B client is a large company that insists on English-only documents, that's a conversation between you and their legal team — but from your side, a bilingual invoice eliminates any compliance question.
What Actually Changed With Loi 96 for Freelancers?
Honestly, not as much as the headlines suggested. The core invoice rule (French required) already existed under the original Charter. What Loi 96 changed that matters to freelancers:
- Purchase orders and similar documents were added to the list of required-French documents
- The French version must be accessible under at least equally favorable conditions as any English version — you can't charge extra or make French harder to access
- Contracts of adhesion must now be offered in French first (since June 1, 2023), before the other party can request another language
- Penalties for violations are higher and enforcement is stronger
Penalties for Non-Compliance
Since Loi 96, the fine structure for Charter violations is:
- Individuals: $700 to $7,000 per offense
- Corporations: $3,000 to $30,000 per offense
- Second offense: fines doubled; third and subsequent: tripled
- Each day a violation continues counts as a separate offense
In practice, the OQLF rarely jumps straight to fines. The typical sequence is: someone files a complaint → OQLF investigates → issues a formal notice requiring correction → if the violation persists, enforcement escalates. For most freelancers, correcting a non-compliant invoice is straightforward — adding French resolves the issue.
The real exposure isn't a one-time fine on a single invoice. It's continued, systemic non-compliance — invoicing Quebec clients in English-only for months or years after being put on notice.
What a Compliant Invoice Looks Like
A Loi 96-compliant invoice for a Quebec client includes these elements in French (bilingual is fine):
- Your name or business name (and GST/QST registration numbers if applicable)
- Client name and address
- Invoice number and date
- Description of services rendered — in French
- Subtotal, applicable taxes (TPS/GST + TVQ/QST), and total — with French labels
Note that Loi 96 compliance and CRA compliance overlap here. A CRA-compliant invoice with French labels satisfies both requirements.
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What If You're Based Outside Quebec?
The Charter applies to enterprises doing business in Quebec — not just those physically located there. If you regularly invoice Quebec clients (especially consumers), you are likely considered to be doing business in Quebec for the purposes of the Charter. Using bilingual invoices is the safest approach regardless of where you're based.
Frequently Asked Questions
My Quebec client says English invoices are fine. Is that enough?
For negotiated contracts (not adhesion contracts), both parties can agree to use another language. But this applies to contracts — not invoices. For invoices, the mutual consent exception is less clear-cut. A bilingual invoice is always the safest approach and eliminates the question entirely.
I'm based in Ontario. Does the Charter apply to me?
Yes. The Charter applies to enterprises doing business in Quebec, regardless of physical location. If you regularly send invoices to Quebec addresses, you are considered to be doing business in Quebec.
Do quotes and purchase orders also need to be in French?
Yes. Loi 96 explicitly added purchase orders and similar documents to the list of required-French commercial documents. Quotes and proposals going to Quebec clients should be bilingual.
My invoicing tool only generates English invoices. What's the fastest fix?
Switch to a tool that supports bilingual output, or add a French section manually. The key requirement: the French version must be at least as prominent as the English. Adding a French header and label translations to an otherwise identical invoice satisfies the requirement.
The Bottom Line
For most freelancers, Loi 96 compliance on invoicing comes down to one simple rule: include French on your invoices to Quebec clients. Bilingual invoices cover every scenario. The francization bureaucracy (OQLF registration, language programs) doesn't apply to solo operators.
If your invoicing tool already produces French or bilingual invoices — you're done. If it doesn't, that's worth fixing before your next Quebec client invoice.
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