Quebec Law 25 and biometrics: identity verification guide (2026)
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Quebec Law 25 applies to selfie-to-ID facial matching as biometric identity verification, requiring businesses to disclose the process to the Commission d’accès à l’information before use and obtain each person’s express consent under section 44 of the IT Framework Act. Organizations must offer a functional non-biometric alternative to people who decline or withdraw consent, collect only necessary biometric information, avoid secondary uses, and destroy biometric records once verification is complete. If face images or templates are stored in a biometric database, section 45 requires prompt declaration to the CAI at least 60 days before deployment, and the regulator may restrict, suspend, or prohibit the database. Data sent to vendors outside Quebec, including elsewhere in Canada, requires a privacy impact assessment and a written agreement demonstrating adequate protections, while automated decisions require notice and an opportunity for human review. The guidance highlights CAI enforcement involving facial-recognition projects, potential administrative penalties up to CAD 10 million or 2% of worldwide turnover and penal fines up to CAD 25 million or 4%, and related federal PIPEDA guidance, while noting that proposed federal Bill C-36 was not yet law as of October 2026.
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