Guide · 2026-10-23

Quebec's Law 25 and AI training data: a plain-English checklist

Short answer: Under Quebec's Law 25, de-identified information is still personal information, so licensing it to an AI developer outside Quebec calls for a privacy impact assessment and a written agreement protecting it. Only information that is irreversibly anonymized falls outside the law. Elsewhere in Canada, PIPEDA governs personal information that crosses borders.

Quebec treats de-identified data as personal information. Here's what that means for licensing records to a US AI buyer.

Last updated · Sources linked inline · Buyer figures observed Oct 16, 2026

If your firm has a Quebec office or Quebec clients, Law 25 changes the licensing checklist. Here are the points that matter most.

Is de-identified data still personal information under Law 25?

Under Quebec's private-sector privacy law as amended by Law 25, de-identified information (identity no longer direct, but still inferable) remains personal information. Only information that is irreversibly anonymized falls outside it.

What is needed before data leaves Quebec?

Communicating personal information outside Quebec calls for a privacy impact assessment and a written agreement that protects it. A licence to a US buyer is exactly that kind of communication.

Does PIPEDA also apply?

Elsewhere in Canada, PIPEDA governs personal information that crosses provincial or national borders. See the OPC's summary.

Do buyers want French-language records?

Most buyer programs say they want English-language records, so mainly French archives may fit fewer of them.

What's on the Law 25 checklist?

  1. Map which records involve Quebec residents
  2. Decide on anonymization or de-identification, and who does it
  3. Complete a privacy impact assessment
  4. Put protections in the written buyer agreement
  5. Record decisions with your privacy officer

Official guidance: Commission d'accès à l'information du Québec. More in our compliance hub.

General information, not legal advice. Buyer figures are as published on the dates shown; verify before relying on them.

What could your firm's records be worth?

Three answers give you a rough range based on what buyers publish. Add your details if you want us to follow up. There's no cost to start.

1 The basics
2 Where your records live (choose any)
3 Canada specifics (optional)
4 Want the breakdown and a call? (only if you want us to follow up)

Both boxes are optional and separate. If you leave them unticked, we'll still reply once about this request. Sender: Firm Data Licensing, firmdatalicensing.ca/contact/. See our privacy policy.