On September 30, 2021, the National Assembly of Quebec adopted An Act to modernize the occupational health and safety regime, commonly referred to as ‘Bill 27’ (Act). Some of the provisions of the Act came into force on October 6, 2025, introducing new employers’ obligations in Quebec regarding psychological health in the workplace. Employers are now required to take the necessary measures to identify, assess and eliminate work-related psychosocial risks.
Psychosocial Risks in the Workplace
Psychosocial risks refer to all workplace-related factors that may adversely affect an employee’s mental or psychological health, such as:
- Chronic or excessive stress related to workload or pace of work
- Psychological or sexual harassment, bullying or violence in the workplace
- A confrontational or tense work environment
- Feelings of isolation, loss of meaning or lack of recognition
- Lack of autonomy or clarity in roles
- Constant pressure, excessive workload or lack of organizational support
The above list is not exhaustive. Any factor that may compromise the psychological health, dignity or emotional security of employees may be considered a psychosocial risk under the Act.
New Obligations for Employers
As of October 6, 2025, employers in Quebec are required to adopt a structured framework for assessing, documenting and monitoring psychosocial risks. More specifically, they must:
- Identify and assess psychosocial risks in their workplace
- Establish procedures for employee participation
- Document Health and Safety Committee (H&S Committee) assessments, prevention plans and decisions, as appropriate
- Continuously monitor and assess the effectiveness of implemented measures
It should be noted that these assessment, documentation and monitoring measures also apply to teleworkers. Employers must therefore identify the specific risks associated with teleworking and take the appropriate measures to prevent such risks.
In addition, the scope of employers’ obligations varies according to the size of the workplace.
Workplaces With 20 or More Employees
For workplaces with 20 or more employees, employers are now required to implement a prevention policy, establish an H&S Committee and designate a psychosocial risk prevention representative.
Prevention Policy: Employers must develop and maintain a formal written program to prevent risks to employees’ health that now must also cover psychosocial work-related risks (Program). The Program must:
- Identify existing risks and establish measures, priorities and timelines for eliminating or controlling the identified risks
- Provide mechanisms for monitoring, evaluation and follow-up
- Include training, awareness-raising and information activities related to psychological health and safety
H&S Committee: An H&S Committee must be set up, composed equally of employer and employee representatives. The H&S Committee’s mandate will be to monitor identified risks, recommend preventative measures and ensure the Program’s effectiveness.
Prevention Representative: At least one prevention representative is to be appointed from among the establishment’s employees. This representative will actively participate in the identification and assessment of risks, including psychosocial risks, and will make recommendations to the H&S Committee. The representative is, by virtue of office, a member of the H&S Committee. The number of representatives and the terms of their respective appointments are to be determined by agreement between the employer and the employees of each establishment.
Workplaces With Fewer Than 20 Employees
Employers with fewer than 20 employees are required to adopt an action plan and appoint a health and safety liaison officer.
Action Plan: Employers must prepare a written action plan aiming to eliminate or, where not possible, control the risks that may affect the health of their employees, including psychosocial risks. This action plan must:
- Identify risks in the workplace
- Establish the necessary measures and priorities for eliminating or controlling such risks
- Provide mechanisms for ongoing monitoring and maintenance
- Include occupational health and safety training and information activities appropriate for the size and nature of the workplace
Health and Safety Liaison Officer: A health and safety liaison officer (H&S liaison officer) must also be appointed from among the company's employees. Acting as an intermediary between the employer and the employees on workplace-related health and safety issues, the H&S liaison officer will be required to complete a training program approved by Quebec’s Commission des normes, de l’équité, de la santé et de la sécurité du travail (CNESST), the provincial body responsible for overseeing workplace standards, pay equity and occupational health and safety. The H&S liaison officer’s duties will include contributing to the development and implementation of prevention measures, including those pertaining to psychosocial risks.
While the scope of these obligations varies with the number of employees in a workplace, it must be noted that the CNESST retains the right to require an employer to establish an H&S Committee or implement a complete prevention program, regardless of the number of employees.
Conclusion
With these legislative changes taking effect, it is essential for employers to assess their level of compliance with these new requirements, update their internal policies accordingly and provide their managers with the necessary training.
For more information, please contact the authors or any other member of our Employment & Labour group.
