Regulation respecting complaint processing and dispute resolution in the financial sector comes into force in Quebec

The Regulation respecting Complaint Processing and Dispute Resolution in the Financial Sector (“Regulation”) came into force in Quebec on July 1, 2025. The Regulation provides for new obligations relating to complaint handling and management requirements for insurers, financial services cooperatives, authorized deposit institutions, trust companies, credit assessment agencies, dealers and advisers governed by the Derivatives Act (Quebec) or the Securities Act (Quebec), and other financial intermediaries such as persons and partnerships registered as firms, independent partnerships or independent representatives under the Act respecting the distribution of financial products and services. Canadian Investment Regulatory Organization (CIRO) dealer members are currently exempt from certain requirements under the Regulation.

The Regulation requires organizations in the financial industry in Quebec to implement certain procedures and follow prescribed timelines when addressing consumer complaints, which are broadly defined as, inter alia: “any expression of dissatisfaction or reproach about a product or service offered […] and a final response is expected.” (S. 3 of the Regulation).

Organizations must have complaint processing and dispute resolution policies that meet the requirements of the Regulation and make such policies easily identifiable their on their websites, clearly communicate information documents relating to the handling of complaints, take reasonable steps to understand communications received, assist complainants in formulating complaints, communicate in a clear and plain manner, provide a final response to complaints, maintain detailed records of complaints, which include certain prescribed information, continue to communicate following a final response where required, and appoint a complaints officer.

The Regulation imposes time limits for responding to complaints, requiring organizations to acknowledge receipt of a complaint in the prescribed form within 10 days of duly registering it, normally provide a final response within 60 days, and implement an offer within 30 days of acceptance. A streamlined process exists for simpler complaints which may be addressed verbally if a satisfactory resolution can be reached within 20 days.

CIRO dealer members may be exempted from requirements under the Regulation, provided that they are subject to equivalent rules of CIRO approved by the Autorité des marchés financiers.

Currently, such organizations benefit from a temporary limited exemption: Frequently asked questions on the temporary exemption from certain obligations of AMF complaint processing Regulation for CIRO dealer members. It is important to note that the Regulation provides for administrative monetary penalties for non-compliance.

For more information on the Regulation and how it may affect your organization please contact the author.