• On April 2, 2026, the National Assembly of Québec assented to Bill 9, which enacts the new Loi favorisant le vivre-ensemble et encadrant les accommodements pour un motif religieux (roughly translated as “Law promoting social cohesion and regulating accommodations for religious reasons”), whose chapter on accommodations expressly applies to the private sector.
• The accommodation threshold shifts from “undue hardship” to “more than minimal hardship”—a major tightening of the duty of accommodation.
• Québec is taking the opposite path from the one the United States recently took in Groff v. DeJoy (2023).
• This new religious accommodation regime is protected by a double notwithstanding clause, with respect to both the Québec Charter of human rights and freedoms and the Constitution Act, 1982.

Bill 9 reinforces the laicity framework in Québec established by the Act respecting the laicity of the State (commonly known as “Law 21”). It extends laicity obligations to new bodies—including private sector bodies such as childcare centres (CPE), subsidized day care centres, educational institutions accredited for purposes of subsidies, private health institutions under agreement, intermediate resources, and family-type resources (s. 19, amending Schedule I of the Act respecting the laicity of the State). It also prohibits religious practice in places under the authority of these bodies, subject to certain exceptions, and extends the prohibition on wearing religious symbols to their...

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