Banks Avocats — The Legal Weekly

Subject line : Your data, your labels, your market: three clocks ticking this summer

Wednesday, July 8, 2026

Hi there,

July isn’t just patio season — it’s also the season for renewing software, rebuilding websites, and planning fall growth. Three seemingly harmless summer decisions can create very real legal obligations. This week: what Law 25 demands when you switch systems, the OQLF’s new grip on online selling, and why your AI tool deserves a second look before vacation. Then a North American trade signpost that just moved, and Europe sharply lightening its sustainability rulebook. Five minutes — let’s go.

🇨🇦 Quebec

1. Switching software this summer? Law 25 wants an assessment first

The summer reflex is classic: use the slow season to migrate to a new CRM, a new payroll platform, or an AI tool. But since September 2023, Law 25 has required a Privacy Impact Assessment (PIA) before any project to acquire, develop, or overhaul a system that handles personal information. No PIA, no compliant rollout — and the Commission d’accès à l’information (CAI) is now in enforcement mode, with administrative fines reaching up to $10M or 2% of your worldwide turnover.

Do this week: List the tools you plan to adopt or replace before the fall. For each one that touches client or employee data, block an hour to start the PIA now — it’s far quicker to do before you sign the contract than after.

2. The OQLF can now shut your online store’s door on Quebec shoppers

Everyone knows the signage rules. Here’s the angle that catches retailers off guard: Bill 96 gives the OQLF the power to order an online seller to block Quebec buyers from purchasing a product whose packaging or labelling doesn’t comply with French-language rules. In other words, a translation gap is no longer just a fine — it can cut you off from a market of nearly 9 million people until you fix it.

Do this week: Review your product pages, packaging, and digital labels. If an item sells into Quebec with an English-only description, correct it before someone else flags it for you.

3. Automated decisions: if an algorithm says “no” to your customer, you need to be able to explain it

More and more businesses let a tool make the call — credit approvals, résumé screening, dynamic pricing. Law 25 is clear: when a decision is based exclusively on automated processing, you must inform the person no later than when you notify them of the decision, and, on request, explain the information and factors used. The right to data portability (in force since September 2024) adds a layer: on request, you must be able to hand over a structured digital copy of the person’s information.

Do this week: Map every place where software makes a decision “on its own” about a customer or applicant. Make sure you have a plain-language sentence ready to explain how that decision was reached.

🍁 Elsewhere in Canada

CUSMA shifts to annual reviews — your export calendar just changed

On July 1, the deadline for the joint review of the Canada–United States–Mexico Agreement (CUSMA) passed with no deal to extend the agreement to 2042. The result: CUSMA stays in force, but shifts to annual reviews until its scheduled expiry in 2036. For exporters, the deal holds — but the planning horizon just shrank from a generation to one year at a time. Meanwhile, Washington is continuing consultations and hearings on new tariff measures affecting several partners, Canada included.

Why it matters: If your cross-border supply or sales contracts assume a stable framework through 2042, now’s the time to check your force majeure, price-adjustment, and change-of-law clauses. An annual cycle changes how you draft — and how you protect yourself.

🌍 International

Europe just lightened its sustainability rulebook — and it reaches your EU customers

On July 3, the European Commission adopted revised, lighter sustainability standards — the latest step in the “Omnibus” package simplifying the Corporate Sustainability Reporting Directive (CSRD). The shift is big: scope narrows to companies with more than 1,000 employees and over €450M in net turnover, and listed SMEs are now fully exempt. The Commission is also due to publish “voluntary” standards for smaller companies by July 19.

Why it matters: Good news if you feared getting swept into the EU net — many companies are now out. But the ripple effect remains: your larger EU customers or lenders still in scope will keep asking you for sustainability data as a condition of doing business. That voluntary standard may quietly become the default question in EU tenders.

💼 Business for sale?

Thinking about buying or selling a business? Banks Avocats guides owners through valuation, due diligence, and closing — on both sides of the deal. Email us atcontact@banksavocats.com to start a confidential conversation.

About the author Jade Banks is a lawyer and the founder of Banks Avocats. She advises entrepreneurs and executives in Quebec and across Canada on business law: incorporations, buying and selling businesses, commercial contracts, and compliance (Law 25, the Charter of the French Language). Her approach: plain language, practical advice, and real attention to your business goals. She and her team write this newsletter every Wednesday.

This newsletter is general information, not legal advice. Reading it does not create a lawyer-client relationship. For advice tailored to your situation, contact a lawyer at Banks Avocats.

Banks Avocats ·banksavocats.com​