Quebec's sweeping new secularism law now in force, pushing organizations to revise religious policy
A new compliance reality took hold in Quebec's workplaces Tuesday, when the Société de transport de Montréal (STM) – Montreal's public transit agency – instructed employees that praying on company property is no longer permitted under the province's newly enacted secularism legislation.
The change stems from Bill 9, An Act respecting the reinforcement of laicity in Québec, which the National Assembly of Québec adopted on April 2. The legislation extends Quebec's existing framework of secularism laws, building on Bill 21 – which restricted religious symbols for public servants in positions of authority – and Bill 94, which expanded those restrictions across school environments in 2025.
Bill 9 bans prayer in public places and in public institutions as of Sept. 1.
The STM had previously made four quiet rooms available to staff for activities including prayer, meditation, yoga, and relaxation. Those rooms will remain open for non-religious quiet use, according to CTV News. "Effective Sept. 1, prayer will no longer be permitted in these rooms or anywhere else on STM facilities and grounds," an STM spokesperson told CTV News, noting that signs have been posted at room entrances to communicate the policy change and supervisors who observe religious practices on company property are expected to address the matter directly with the employee involved.
A lower bar for refusing religious accommodation
With Bill 9 coming into force, organizations operating across Quebec's public and private sectors are seeing a legal shift that reaches beyond prayer rooms.
Canada has long applied an "undue hardship" standard for religious accommodation – a high threshold requiring employers to demonstrate significant financial cost, operational disruption, or health and safety risk before denying a request. Bill 9 replaces that benchmark with a more restrictive "more than minimal hardship" standard, according to a blog by law firm Ogletree Deakins after Bill 9 was passed. This new standard applies to the private sector as well as the public sector, as specified in s. 5 of the new legislation.
This accommodation shift is the "sleeper" issue within the legislation, Pearl Eliadis, associate professor at McGill University's Max Bell School of Public Policy in Montreal, said in an interview with Canadian HR Reporter in April. In practice, the lowered threshold means employers in Quebec may now legally decline accommodation requests that result in moderate operational disruption, costs that fall short of being substantial, or effects on team efficiency or on the working conditions of other employees.
“I think the broad pattern here is one of rejecting the, I would say, ‘Canadian approach’ to multiculturalism and tolerance, and rejecting the implications of that for flexible workplaces, with regard to religious minorities,” Eliadis told Canadian HR Reporter.
As the Quebec government pushes for further restrictions on religious symbols, services, and prayers in workplaces, Bill 9 marks one of the most consequential legal changes for Quebec employers in recent years. HR teams that have not yet reviewed their religious accommodation policies in light of the new legislation should do so as a matter of priority.
Workforce planning risks across key sectors
The cascading workforce effects of Quebec's escalating secularism framework are already visible in some of the province's most heavily staffed public sectors.
Quebec's expanded secularism rules for daycare workers under Bill 9 have prompted significant concern about deepening staff shortages in a sector already struggling to recruit. Daycare operators have warned that the legislation is creating fear and uncertainty, with little guidance about how it will be applied day-to-day, CBC News reported in April. The Coalition Avenir Québec (CAQ) government announced a one-time transition payment per affected educator – an amount sector advocates described as insufficient to address the depth of disruption.
Bill 9 also removes prayer rooms from colleges (collèges d'enseignement général et professionnel, or CEGEPs) and universities, and bans collective prayer in public spaces such as streets and parks without explicit municipal consent. Each of these provisions carries direct implications for workforce planning, organizational culture, and the lived experience of employees whose religious practice has been part of their working day.
Stephen Brown, president of the National Council of Canadian Muslims (NCCM), questioned the premise of the legislation when it was tabled. "The real question for me is what problem are we actually solving? Nobody said that this was an issue," Brown told Global News.
What HR leaders operating in Quebec should do now
Quebec's approach to secularism places HR leaders in the province in a fundamentally different legal and cultural environment than their counterparts elsewhere in Canada – a divergence that’s widening with each successive piece of legislation.
The notwithstanding clause in spotlight at Supreme Court hearings on Bill 21 exposed a sharp divide between provincial and federal approaches to religious expression in the workplace – a legal uncertainty that remains unresolved. For now, HR leaders must navigate the rules as they stand.
Immediate priorities for HR and legal teams in Quebec include auditing religious accommodation policies against the new "more than minimal hardship" standard, briefing people managers on how to apply that updated framework consistently, and assessing staffing exposure in sectors where the religious symbols provisions could affect recruitment or retention pipelines.
Organizations with cross-provincial operations will need to carefully manage regulatory divergence between Quebec and other Canadian provinces, ensuring that accommodation policies are adapted by jurisdiction and that managers understand the distinct legal obligations that apply where they operate.
