On March 28, a few months after receiving the latest opinion from the Comité consultatif du travail et de la main-d’œuvre (CCTM) on child labour in Quebec, the Minister of Labour, Jean Boulet, introduced Bill 19, An Act respecting the regulation of child labour, which aims to reform the current legislation governing child labour in order to adapt it to the current realities of the labour market and to ensure better compatibility with other Canadian legislation and international conventions. According to Minister Boulet, the two fundamental objectives of this reform are to ensure better educational success for children and protect their health and safety.

The legal framework governing child labour has not been significantly updated since the turn of the millennium and has been the target of criticism, as evidenced by some of the disturbing statistics presented by the CCTM, a tripartite body that includes the Ministère du Travail and business and labour representatives. The Commission des normes, de l’équité, de la santé et de la sécurité du travail, for example, recorded a 392% increase in workplace injuries for youth under 14 and 221% for youth under 15 between 2012 and 2021.

Although more and more in decline,1 dropping out of school is also an important issue that the government wishes to address. In Quebec, a male minor who spends between one and ten hours a week at work has a 21% risk of dropping out of school. More worrying, when the number of hours worked increases beyond 21 hours, the risk of dropping out of school rises to 41%!2

Moreover, the labour shortage that Quebec is currently facing, marked by an all-time low unemployment rate of 3.9% in January 2023,3 is only exacerbating an already existing problem. The shortage leads some employers to be more competitive when recruiting, which can result in job offers with more attractive working conditions, especially for unskilled workers—which in turn can push young people to drop out of school and join the labour market earlier.

What the law now says

From the outset, it should be noted that all legal protections relating to labour law in Quebec apply regardless of the worker’s age and therefore protect both children and adults. As for the employment of minors specifically, unlike most other Canadian provinces, Quebec legislation does not currently set a minimum age for employment, but does impose certain restrictions providing an appreciable level of protection to minor employees.

First, before an employer can even have a child under the age of 14 perform work, the employer must obtain written consent from the holder of parental authority or tutor, usually a parent.4 An employer who has obtained such authorization is required to keep a copy in the employee’s file.

More generally, the law prohibits an employer from requiring a child to perform work that is disproportionate to the child’s capacity or that is likely to be detrimental to the child’s education or physical or moral development.5 Jobs such as butcher or mincer operator in a slaughterhouse have, for example, been deemed by the courts to be too dangerous for children.6

Second, the law provides for some time restrictions to allow children to be present in class so that their employment does not interfere with their schooling. An employer cannot make a child subject to compulsory school attendance work during school hours and must even ensure that the child is given sufficient time, before or after the shift, to attend school during school hours.7 In accordance with the Education Act, every child who is a resident of Quebec must attend school until the last day of the school year in which he or she turns 16 or obtains a diploma issued by the Minister of Education.

In addition, no employer may have work performed by children between 11 p.m. and 6 a.m. This rule does not apply to children who are no longer subject to compulsory school attendance, children engaged in newspaper delivery, or children employed as creators or performers in various fields of artistic production such as stage, music, dance, film, or recording of commercials. In addition to not being able to have work performed during these hours, the employer has an obligation to ensure that the child can be returned home between 11 p.m. and 6 a.m. However, an employer who operates a social or community organization where child workers are housed, such as a summer camp, is not bound by this obligation.8

Lastly, the Quebec legislation includes several other specific restrictions, including minimum age limits for certain dangerous jobs such as underground mining,9 tree felling with a chain saw10 or blasting.11

What Bill 19 does

Largely following the advice of the CCTM, the Bill proposes several major changes to the current legislation to better protect Quebec’s minor workers. In addition to maintaining the existing protections, some are strengthened and new ones are also adopted.

Like most other provinces in Canada, Quebec will now impose a legal limit on the working age. From now on, children under 14 will be prohibited from performing work, unless it falls within one of the following exceptions provided for by the law:

  • Creation and interpretation in an artistic field;
  • Newspaper or other publication delivery;
  • Babysitting;
  • Homework assistance or tutoring;
  • Work in a family business with fewer than 10 paid employees, if the employer, director or partner in the business, or that person’s spouse, is the child’s parent;
  • Work in a non-profit social or community organization such as a camp or recreational organization;
  • Work in a non-profit sports organization to assist another person, or in a support role such as assistant instructor, assistant coach or scorekeeper.

It is important to note that in these last three cases, the work of young people under 14 years of age must nevertheless be carried out under the supervision of an adult.

In addition, the already existing requirement to obtain an authorization duly signed by the parents of a child under 14 years of age is specified. From now on, this authorization will be done via a form provided for this purpose in which the tasks, working hours and availability of the child are detailed. Any subsequent changes to the job will require a new parental consent.

Another key measure introduced by the Minister of Labour to promote academic success is the imposition of a maximum of 17 work hours per week for youth under 16 years of age, with a maximum of 10 hours between Monday and Friday.

Bill 19 also provides for various other measures, such as modifying companies’ occupational health and safety programs to take into account the age of the employees affected, as well as increasing the powers of the Commission des normes, de l’équité, de la santé et de la sécurité du travail to allow it to provide financial assistance to support information, awareness or training initiatives about labour standards.

Finally, to give the legislation more teeth, Bill 19 doubles the minimum fines from the current level, bringing them as high as $12,000 for repeat offenders.

Once the legislation is assented to, Quebec employers will have 30 days to provide notice of termination to employees who are minors and do not meet the new legal requirements, or to obtain the required parental authorization, if applicable. Where the employer is required to provide notice of termination, the period of notice is specifically set out in the Bill. Besides the measures relating to the number of hours worked, which will come into force on September 1, 2023, and those relating to occupational health and safety, which will follow the coming into force of the Act to modernize the occupational health and safety regime, the other provisions of Bill 19 will come into force upon its assent.


While this reform of the legislation governing child labour is important and laudable, it will necessarily result in changes that will have an impact on Quebec employers. This reality is all the more true when we consider the recruitment problems that employers are currently experiencing, and this is why it will be important, over the next few months, to keep an eye on debates in the National Assembly and during the public consultations in order to better understand the guidelines adopted by the Minister of Labour. Employers in Quebec will also need to know the ages of all their employees and ensure compliance with any new requirements coming into effect in the near future.