Quebec Law 25 for MSPs: What It Is and What to Know
Written by: Lizzie Danielson
Published: 11/13/2026
Your client doesn’t need a Quebec office to land on Quebec’s privacy regulator’s radar. One customer in Montreal can do it.
And when that client has a data incident, who gets the first call? You.
Law 25 is Quebec’s overhaul of its private-sector privacy law, and it’s one of the strictest in North America. If you support clients who collect, store, or process personal information about people in Quebec, it’s your business too, even if your name isn’t on the legal hook.
Key Takeaways
- Law 25 is fully in force. Every phase has been in effect since September 22, 2024.
- There’s no small-business exemption. Four employees or 4,000, the baseline rules are the same.
- Penalties can reach $25 million CAD or 4% of worldwide turnover.
- Managed service providers (MSPs) usually aren’t the ones carrying the privacy program, but they hold the evidence, the access, and the incident response that makes it real.
What is Quebec’s Law 25?
Law 25 applies to any organization that does business in Quebec and collects, holds, uses, or shares personal information. That includes for-profit companies, nonprofits, and professionals working in a business capacity. And there’s no size cutoff; a four-person shop faces the same baseline rules as a big enterprise.
It can also reach businesses outside Quebec, depending on how closely their activities connect to people in the province. So a U.S. or Ontario-based client with Quebec customers or employees can be in scope.
Personal information here means anything that identifies a person. Names, emails, health records, payroll data, customer lists, and browsing behavior all count.
What Law 25 requires
Here are the obligations you’ll see come up again and again:
- A named privacy officer: Every organization must designate someone responsible for protecting personal information. By default, that’s the highest-ranking person in the organization, though they can delegate it in writing. The role and contact information must be published on the company’s website.
- Privacy impact assessments (PIAs): Before launching or overhauling an information system or electronic service that handles personal information, the organization must assess the privacy risk. A PIA is also required before sending personal information outside Quebec.
- Incident response and a register: The organization must keep a register of confidentiality incidents. If an incident creates a risk of serious injury, the organization must notify the Commission d'accès à l'information (CAI) and the people affected. The law says to act promptly, but it doesn’t set a number of hours.
- Stronger consent: Consent must be clear, free, informed, and tied to specific purposes. It has to be requested separately from other terms, and sensitive information generally needs express consent. Children under 14 need a parent’s or guardian’s consent.
- Transparency and privacy by default: Organizations must publish privacy policies in clear language and tell people when technology identifies, locates, or profiles them. Products and services offered to the public must default to the highest privacy settings.
- Governance policies: Organizations need written rules for retention and destruction, staff roles and responsibilities, and handling privacy complaints.
- Individual rights: People can ask for access, correction, and data portability, plus de-indexation in some cases. Organizations generally have 30 days to respond.
One more obligation that trips people up: If a client uses biometrics (fingerprint or facial recognition) to verify identity, they must notify the CAI before they start.
What happens if you get it wrong
The penalties are big enough to change how your clients think about privacy:
- Administrative monetary penalties from the CAI can reach $10 million CAD or 2% of worldwide turnover, whichever is greater.
- Penalty fines can reach $25 million CAD or 4% of worldwide turnover, whichever is greater. For corporations, there’s a minimum fine of $15,000.
- Private lawsuits are possible. People can sue for violations caused by intentional misconduct or gross negligence, and punitive damages start at $1,000.
Nobody’s getting fined $25 million over a missing cookie banner. But “we didn’t know” isn’t an excuse, and your clients will want someone with a plan.
Where MSPs fit
Here’s the honest answer: In most cases, your client is the organization legally responsible for the privacy program. You’re a service provider that handles personal information on their behalf.
That doesn’t make you a bystander. Four things put you squarely in the picture:
- Contracts. Law 25 expects a written agreement with service providers who handle personal information for the client. It should cover security measures, using the information only for the contract’s purpose, not keeping it after the contract ends, and telling the client without delay about any breach or attempted breach.
- Data leaving Quebec. If you use U.S.-hosted tools for remote management, ticketing, backups, or documentation, personal information may be crossing the border. The client has to complete a PIA first, and they’ll need your security documentation to do it.
- Incidents. You’ll often be the first to spot trouble. The client needs your facts fast so they can decide whether to notify the CAI and the people affected.
- Your own data. If you carry on business in Quebec, you’re an organization too. That means your own privacy officer, policies, and assessments for your marketing lists, employee records, and client contacts.
The practical model: the client owns the privacy program. You supply the technical controls and the evidence that prove it works.
What MSPs should watch for
The vendor stack nobody mapped. Every tool that touches client personal information is part of the story. Keep a current list of where the data lives, who processes it, and what contract covers it.
“We’ll figure out the incident process later.” The register and the notification decision depend on fast, accurate facts. If your escalation path lives in someone’s head, fix that now.
French-language gaps. Quebec has French-language requirements for customer-facing documents, including privacy policies. If your client serves Quebecois customers, their policy should be available in French.
Consent and tracking. Cookie and tracking tools usually need opt-in consent in Quebec. If you manage client websites, check what’s loading before the visitor says yes.
Treating this as a one-time project. A privacy policy written once and never revisited is exactly how clients drift out of compliance. Law 25 rewards ongoing work.
How Law 25 maps to the work you already do
Most of the technical baseline overlaps with what you run for frameworks like HIPAA, SOC 2, or CIS Controls. The Quebec-specific part is the paperwork: the privacy officer designation, the PIAs, and the CAI-facing incident process.
Law 25 expectation | What it looks like in MSP work | Where Huntress fits |
Reasonable security safeguards | Layered security controls (identity and access, endpoint protection, timely offboarding), documented and reviewed on a set schedule, similar to the controls attested to in a SOC 2 Type 2 | The Huntress agentic platform brings endpoint, identity, and security posture protection together, so you can show clients which layers are in place and keep them current |
Spotting confidentiality incidents | Detect, investigate, and scope what was accessed | The platform pairs detection with 24/7 human-led AI-centric SOC investigation, giving you the signal and the detail |
Incident register and CAI decision | Record facts, timeline, and risk assessment | Incident reports and log data from the platform can be fed into the client’s register |
Staff handling of personal information | Security awareness training and simulated phishing awareness training | Security awareness training sits on the same platform, so training records live alongside your other evidence |
Vendor contracts and cross-border PIAs | Inventory, agreements, security documentation | Your inventory and security documentation give clients what they need to complete their PIAs and vendor reviews, and platform records back it up. If a client wants to reduce potential cross-border access to information that Huntress collects, Sensitive Data Mode can be used to restrict SOC access by permanently blocking specific file extensions from host data transfers. |
One thing worth saying plainly: No product makes anyone Law 25 compliant. Most of the law is governance, documentation, and decisions only your client can make. What tools do is produce the evidence that those decisions were backed by real security.
Turn Law 25 into a recurring service
If you sell this as a one-time policy pack, you’ll leave money and protection on the table. A better approach is a service that produces proof on a schedule:
- Initial engagement. Confirm the client’s privacy officer, map personal information and data flows (especially anything leaving Quebec), complete the needed PIAs, refresh service-provider agreements, set up the incident register and notification process, and update the privacy policy.
- Monthly. Review access and MFA, track new tools that need a PIA, log and triage potential incidents, and send the client a short summary.
- Annual. Refresh the data map and PIAs, run an incident tabletop, confirm training is done, and hand over a readiness report the client can show insurers or larger customers.
That same evidence helps with cyber insurance applications too, which increasingly ask about privacy programs, incident response testing, and vendor controls.
Law 25 and PIPEDA
If your clients operate across Canada, you’ll run into the federal law, Personal Information Protection and Electronic Documents Act (PIPEDA), as well. They share themes like consent, safeguards, and breach notification, but Quebec’s rules are stricter on assessments, portability, and penalties. Many MSPs offer a base Canadian privacy service and add a Quebec tier for clients with Quebec-resident data.
A quick Law 25 checklist for MSPs
- Do you know which clients have Quebec customers, employees, or data?
- Does each one have a named privacy officer, with contact info published?
- Do you have written service-provider agreements that cover the Law 25 basics?
- Have PIAs been done for systems and transfers that send data outside Quebec?
- Is there an incident register, and a documented path from “we found something” to “the client decides”?
- Is MFA enforced and documented across client environments?
- Are staff trained on handling personal information?
- Are privacy policies current, written in plain-language, and available in French where needed?
If you answered “I don’t know” to more than two, start there.
Be the partner who saw it coming
Law 25 isn’t going away, and your clients won’t read the statute themselves. They’ll look at the people who already keep their lights on.
Know the rules. Map the data. Document the incidents. Prove the controls work. That’s what turns a scary regulation into a service clients are glad they bought.
Explore the Huntress agentic security platform and see how our solutions work together all backed by a 24/7 human-led AI-centric SOC, to give you the security and the evidence behind it.
FAQs
It can, in two ways. If you carry on business in Quebec or hold personal information about people there, you may be an organization under the law. And if your clients are in scope, their contracts and data practices flow through to you.
No. A four-person firm faces the same baseline rules as a large enterprise.
Law 25 says to act promptly when an incident creates a risk of serious injury, but it doesn’t set a specific number of hours. Don’t wait for certainty. Gather facts quickly and get them to the client.
Quebec’s law governs most private-sector privacy in the province. PIPEDA can still apply to cross-border data flows and federally regulated businesses, so many clients end up with both.
Yes, for legal interpretation. This article explains the landscape, but it isn’t legal advice. Work with Quebec counsel when you’re writing contracts or deciding whether to notify the CAI.
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