In keeping with its recent renewed interest in establishing robust protections for consumers within the province, the government of Québec tabled a new bill on December 2, 2025 amending the Québec Consumer Protection Act (“CPA”). Known as Bill 10, An Act to protect consumers against abusive practices in ticket reselling and online subscription renewal (“Bill 10” or “the Bill”), the main objective of the proposed legislation is to amend the CPA with regard to ticket sales and contracts involving sequential performance, such as online subscriptions. The legislation proposes significant penalties for non-compliant sellers of online goods and services, as well as ticket resellers.
Note that some of the newly introduced provisions described below apply not only to consumer contracts, but also to certain contracts between merchants – for example, where the producer of an event enters into an agreement with a ticket reseller.
Note also that Bill 10 has only just been introduced and may still be amended. There is as yet no in-force date.
Contracts Involving Sequential Performance
With respect to contracts involving sequential performance that the consumer may resiliate (i.e., cancel) without cause (e.g., online subscription services), Bill 10 requires that merchants who enter into such contracts online make available to the consumer a readily identifiable button that allows the consumer to exercise that right of resiliation.
Bill 10 also requires merchants who enter into contracts for sequential performance with consumers under which goods or services are supplied at a reduced price (or free) for a certain period to send to the consumer, within 2 to 10 days before that period ends, a written notice drawn up clearly and legibly indicating the end date and the price that will apply after that date.
In addition, as concerns contracts involving sequential performance for services provided at a distance (e.g., contracts for telephone or cable television services), Bill 10 requires merchants who announce the amount of the instalments to be paid to obtain such a service to indicate, clearly and legibly, next to that amount, the amount of the fees charged other than by instalments. Where the merchant announces the amount of the instalments orally, the amount of such fees must be mentioned immediately after the announcement of the amount of the instalments.
Online Reviews
Bill 10 prohibits any stipulation that would have the effect of prohibiting a consumer from publishing or communicating a review concerning goods or services offered by a merchant or concerning a merchant’s conduct.
Ticket Sales
Bill 10 requires anyone who operates a digital ticket resale platform to inform the consumer, in a prominent and intelligible manner, as soon as the consumer accesses the platform, of the fact that it is a ticket resale platform and that tickets may be available at a lower price from the vendor authorized by the producer of the event. Where tickets are offered both for sale and resale on a digital platform, the consumer must be informed, at the same time and in the same manner, that certain tickets available on the platform are being resold.
Additionally, Bill 10 specifies that the following information must be expressly brought to the attention of the consumer before any resale of tickets:
- The identity of the vendor authorized by the producer of the event;
- The possibility that tickets may be available from that vendor and the price advertised by that vendor;
- The fact that the ticket is being resold;
- The place or seat the ticket allows the ticket holder to occupy, unless the ticket does not assign one; and
- The name of the last owner of the ticket.
Bill 10 also prohibits the resale price charged for a ticket from being higher than the price announced by the vendor authorized by the producer of the event, unless:
- The consent of the producer of the event to the resale of the ticket at a higher price was obtained first;
- The ticket is resold in compliance with the agreement entered into with the producer of the event; and
- The maximum resale price of the ticket agreed to by the producer of the event has been expressly brought to the attention of the consumer before the resale.
When it comes to event cancellations or modifications, Bill 10 gives the producer of an event the obligation to inform, as soon as possible, (i) the authorized vendor and (ii) if applicable, any reseller with whom the producer entered into an agreement, of the cancellation of the event or of any modification to its schedule or location. Anyone who sells or resells a ticket to a consumer must also, as soon as possible, inform the consumer of the cancellation of the event or of any modification to its schedule or location.
Bill 10 also establishes a presumption according to which anyone who allows a third person to resell a ticket by a technological means (i.e. through an online platform) is subject to certain existing obligations and new obligations concerning the sale of tickets, including that:
- No merchant may sell a ticket to a consumer at a price above that announced by the authorized vendor, unless the merchant clearly informs the consumer before reselling the ticket: (i) of the identity of the authorized vendor, of the fact that tickets may be available from the latter and of the advertised price of the tickets; (ii) that the ticket is being resold and, where applicable, of the maximum resale price agreed to by the producer of the event; and (iii) of the place or seat the ticket authorizes the ticket holder to occupy, unless no specific place or seat is assigned by the ticket.
- No person may resell, or facilitate the resale of, a ticket obtained using software enabling the purchase of tickets by circumventing a security measure or control system put in place by the producer of a show or by the authorized vendor.
- Anyone who sells or resells a ticket to a consumer must also, as soon as possible, inform the consumer of the cancellation of the event or of any modification to its schedule or location.
- No person may resell a ticket without first informing the consumer that the price paid for the ticket will be refunded to the consumer if: (i) the event to which the ticket grants admission is cancelled; (ii) the ticket does not grant the buyer admission to the event for which the ticket was purchased; or (iii) the event to which the ticket grants admission, the place or seat the ticket authorizes the ticket holder to occupy or the value of the ticket does not correspond to the representations made to the consumer.
- No person may resell a ticket that is not in her possession or under her control.
The Bill also prohibits charging fees for the transfer of a ticket.
We would note that, unlike most provisions of the CPA which refer to a merchant or manufacturer, these new provisions refer to “anyone.” Their scope may therefore also include natural individuals reselling tickets, rather than being limited to merchants doing so in the course of their business.
Penalties
The Bill provides that a merchant who fails to fulfil an obligation to not claim an amount from a consumer must make restitution of that amount, regardless of any prestation[1] provided as consideration and without infringing on the consumer’s other rights and recourses. That obligation applies in particular in the case of a failure to comply with:
- The obligation not to charge a higher price for goods or services than that advertised;
- The obligation not to charge any sum whatever for any goods or services sent or rendered to a consumer without the consumer having ordered them;
- The obligation of a credit broker not to charge or collect payment from a consumer for services rendered or to be rendered;
- The obligation of a surety not to charge or collect payment from a consumer to enable her to enter into a credit contract;
- The obligation of a merchant not to sell a ticket to a consumer at a price above that announced by the authorized vendor, unless the prescribed conditions listed above are respected; or
- The obligation not to charge a consumer for exchanging or cashing a cheque or other order to pay issued by the government of Québec or of Canada or by a municipality.
Bill 10 also imposes administrative monetary penalties and penal fines for these new obligations, listed in the table below.
Collection Agent Permits
In addition to the above, Bill 10 allows the president of the regulatory body, the Office de la protection du consommateur, to suspend or cancel a collection agent permit if the holder of the permit:
- No longer meets the requirements prescribed by the CPA or the regulations made thereunder for the issuance of a permit;
- Is not in a position, by reason of her financial condition, to assume the obligations arising from her business; or
- If she is unable to ensure, in the interest of the public, honesty and competence in collection agents’ activities.
[1] A prestation is the object of an obligation, and consists in doing or in not doing something.
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