On December 2, 2025, the Québec Minister of Justice introduced Bill 10, An Act to protect consumers against abusive practices in ticket reselling and online subscription renewal (the “Bill”), which amends the Consumer Protection Act (CPA). The Bill aims to provide better consumer protection in certain areas and to ensure that consumers have access to clearer information.
The Bill has made headlines primarily for its new requirements regarding ticket resales and the governance of that segment of the entertainment industry. But its scope is much broader, affecting multiple aspects of merchants’ obligations in various sectors.
We currently do not know when the Bill and its amendments to the CPA and the Regulation respecting the application of the Consumer Protection Act might take effect. Some provisions may also be phased in to allow merchants to adjust to their new obligations.
Proposed amendments to the CPA
1. “Cancellation button” for online contracts involving sequential performance
Under the proposed new section 187.28, a merchant who enters into an online contract involving sequential performance that the consumer may cancel without cause must make available a button that is accessible online and readily identifiable allowing the consumer to easily exercise that right of cancellation.
This provision, as currently drafted, does not differentiate between the types of online contracts involving sequential performance, or the types of products or services such contracts may concern.
Since consumer law and general civil law allow the consumer or client to terminate most contracts without cause (subject to possible contractual and legal consequences), many merchants could be forced to review their practices and provide a cancellation button on their online platforms.
2. Notice of renewal at a higher price
Under the proposed new section 187.29, where a consumer has entered into a contract involving sequential performance which provides that goods or services are supplied free of charge or at a reduced price for a determinate period, and that, at the expiry of that period, they will be provided at a higher price, the merchant must send to the consumer a written notice drawn up clearly and legibly indicating the date of the end of that period and the price that will be applicable from that date onwards.
According to the Bill’s proposed amendments to the Regulation respecting the application of the Consumer Protection Act, the notice must be sent 2 to 10 days before the end of the period during which the goods or services are supplied free of charge or at a reduced price.
Section 230 (c) of the CPA already provides that a consumer receiving services or goods free of charge or at a reduced price for a fixed period cannot be required to send a notice at the end of that period to indicate not wishing to obtain the services or goods at the regular price. That provision has already been construed by the case law which found that the existence of a promotional price for a certain period within a longer contract term did not violate the CPA.
The scope and application of the proposed new section 187.29 will likely depend on the nature, conditions and term of the contract and whether it is a fixed-term or open-ended contract.
3. Disclosure of instalments paid for a sequential performance service provided at a distance
The proposed new section 214.1.1, included in a division of the CPA about “contracts involving sequential performance for a service provided at a distance,” provides that a merchant who announces the amount of the instalments to be paid to obtain a sequential performance service provided at a distance must indicate, clearly and legibly, next to that amount, the amount of the fees charged other than by instalments to obtain the service.
This new section, as currently drafted, seems to specifically concern the payment of services provided at a distance that are performed sequentially, and not the payment of goods under such a contract.
It also does not mention the temporal reference for indicating the value of services other than the frequency of instalments set out under the contract. On its face, it seems likely that this new provision will create difficulties for indeterminate contracts involving the sequential performance for a service provided at a distance.
4. Ticket reselling
One of the Bill’s key aspects, the regulation of ticket reselling, introduce the following measures:
- Under proposed new section 236.0.1, anyone who operates a digital platform dedicated to reselling tickets must, as soon as the consumer accesses the platform, inform the consumer, in a prominent and intelligible manner, 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. In addition, 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 tickets being resold. However, this provision does not specify how the platform user is to be informed of said elements.
- Under proposed new section 236.1, no person may resell a ticket without having, first, expressly brought to the attention of the consumer various information, including 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 that vendor announces, the fact that the ticket is being resold, the place or seat, and the name of the last owner of the ticket. This last point could raise concerns about the protection and sharing of personal information, which will have to be addressed. The new provision also stipulates that the resale price charged for a ticket may not be higher than the price announced by the authorized vendor unless the producer’s consent was obtained first, that the resale is in compliance with the agreement entered into with the producer of the event, and that the maximum price agreed to by the producer of the event has been brought to the attention of the consumer. As a reminder, the CPA defines “ticket” as any document or instrument that, on presentation, grants the ticket holder admission to a show, sporting event, cultural event, exhibition or any other kind of entertainment.
- Proposed new sections 236.2.1, 236.2.2, 236.5 and 236.6 establish new obligations regarding notification requirements if an event is cancelled or the time or location is changed, prohibit charging fees for the transfer of a ticket, and create a presumption of ticket resale for operators of resale platforms between third parties.
5. New remedy: Restitution
Under proposed new section 272.1, and without prejudice to the consumer’s rights and recourse under CPA section 272, a merchant who fails to fulfil an obligation not to claim an amount from a consumer under the CPA, a regulation, or a voluntary undertaking must restitute that amount to the consumer, regardless of any other prestation provided as consideration.
The scope of section 272.1 is not limited to the new provisions introduced by the Bill and could cover any breach of the CPA resulting in the consumer paying an amount that the merchant was not entitled to charge, for one reason or another.
This provision, added to the CPA’s chapter on Civil Recourses, seems designed to address concerns about the nature or extent of the restitution of prestations under civil law whenever a contract has been only partially performed, or not performed as stipulated.
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Conclusion
Lastly, the Bill amends the Regulation respecting the application of the Consumer Protection Act to prohibit any stipulation preventing a consumer from publishing or communicating a review concerning products or services offered by a merchant or a merchant’s conduct.