Bill 10: Tightening of the applicable rules regarding restitution to consumers of amounts charged in contravention of the CPA, online subscriptions and the resale of tickets

An Act to protect consumers against abusive practices in ticket resale and online subscription renewal (Bill 10) was adopted on June 12, 2026. It amends the Québec Consumer Protection Act (CPA) and its regulations to create an obligation to restore certain amounts collected from consumers in contravention of the CPA, and to strengthen the rules governing e-commerce and ticket resale.

Bill 10 requires merchants to send clear notices regarding the end of trial or promotional periods for contracts involving sequential performance, to disclose more clearly any non-recurring costs applicable to such contracts, and to provide an easily accessible online option to cancel subscriptions. It also tightens the legislative and regulatory framework governing the secondary ticket market and introduces measures aimed at protecting consumers’ freedom of expression. Bill 10 also establishes an obligation to restore amounts collected from consumers in contravention of the CPA, without prejudice to the rights and remedies already available to consumers under the CPA.

Most provisions of Bill 10 will come into force on September 12, 2026; some took effect immediately when it was assented to on June 12, 2026¹.

Restitution of amounts charged in contravention of the CPA

Bill 10 provides that a merchant who charges a consumer an amount in contravention of the CPA, a regulation, or a voluntary undertaking entered into under the CPA, must restore that amount to a consumer who seeks a reduction of their obligation, regardless of any performance of services provided in return². This provision has been in force since Bill 10 was assented to on June 12, 2026.

This restitution obligation applies in particular where there is a failure to comply with

• the prohibition against charging, for a good or service, a price greater than the advertised price³;
• the prohibition against charging any amount for a good or service that the merchant, manufacturer or advertiser has sent or rendered to a consumer without the consumer having requested it⁴;
• the prohibition against a credit broker demanding or receiving full or partial payment from a consumer for services rendered or to be rendered⁵;
• the prohibition against a surety charging or collecting full or partial payment from a consumer to enable the consumer to enter into a credit contract⁶;
• the prohibition against charging, for the resale of an event ticket, a price higher than the price listed by the vendor authorized by the event producer, except where the applicable conditions (discussed below) are met⁷; and,
• the prohibition against charging a consumer fees for the exchange or cashing of a cheque or other payment instruments issued by the Government of Québec, the Government of Canada, or a municipality⁸.

This restitution of amounts under this obligation does not otherwise limit the consumer’s rights to seek additional remedies where a merchant or manufacturer fails to comply with an obligation imposed by the CPA⁹. This amendment, now set out in section 272.1 of the CPA, is declaratory¹⁰. The Committee Report states in its comments that this amendment “does not introduce a new right into the [CPA], but is deemed to have always formed part of it” [translation]¹¹.

Online subscriptions and termination (resiliation)

As of September 12, 2026, any merchant who enters into an online contract involving sequential performance will be required to make available to consumers an easily identifiable online button, allowing them to exercise their right of termination (resiliation)¹². The Minister of Justice indicated that he wanted to put an end to the “digital labyrinth” that consumers are forced to navigate to unsubscribe from online services¹³.

If such termination could result in the loss of a telephone number, the merchant must, prior to termination, expressly bring that information to the consumer’s attention and inform the consumer of the steps required to keep the number¹⁴.

Free or reduced-price promotional periods and non-recurring fees

Where a consumer has entered into a contract involving sequential performance that provides that a good or service is supplied free of charge or at a reduced price for a determinate period, and that, at the expiry of that period, it will be supplied at a higher price, the merchant must send the consumer a clear and legible written notice indicating the end date of that period and the price that will apply as of that date¹⁵. This notice must be sent to the consumer between two and ten days before the end of the period during which the good or service is supplied free of charge or at a reduced price¹⁶. This new requirement will not apply to contracts already in force on the date the new provision comes into force¹⁷.

Bill 10 also introduces an obligation to disclose non-recurring fees in service contracts involving sequential performance. Accordingly, where fees charged other than on a periodic basis are added to the periodic instalments required to obtain the service, the amount of those fees must be indicated clearly and legibly near the amount of the periodic instalments. If those fees are disclosed verbally, their amount must be mentioned immediately after the amount of the periodic instalments is announced¹⁸.

Clauses prohibiting consumer reviews

Bill 10 also expressly prohibits, by regulation, any contractual stipulation that would have the effect of preventing a consumer from publishing or communicating a review concerning goods or services offered by a merchant or the merchant's conduct¹⁹. According to the Minister of Justice, this is an emerging practice in consumer contracts in the United States²⁰, which he wishes to prevent through a clear legislative message in Québec. This provision has been in force since Bill 10 was assented to on June 12, 2026²¹.

Ticket resale

Merchants operating a digital platform dedicated to the resale of event tickets will have to inform consumers, prominently and intelligibly, as soon as they access the platform, that the platform is a ticket resale platform and that tickets may be available at a lower price from the vendor authorized by the producer of the event²². Where tickets are offered both for sale and resale on a digital platform, consumers must be informed, at the same time and in the same manner, that certain tickets available on the platform are resale tickets²³.

Ticket resellers will also have to indicate the name of the last owner of the ticket²⁴. This requirement is in addition to the existing obligation to bring the following information to the consumer’s attention before any ticket resale:

1. 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 listed by that vendor;
2. the fact that the ticket is being resold; and
3. the location or seat that the ticket allows the holder to occupy, unless the ticket does not assign any specific location or seat²⁵.

Bill 10 also provides that the price charged for the resale of an event ticket may not exceed the price listed by the vendor authorized by the producer of the event, unless the maximum resale price of the ticket to which the producer of the event has consented has been expressly brought to the consumer’s attention before the sale²⁶. This new requirement is in addition to the following existing obligations:

1. the consent of the producer of the event and, if applicable, the promoter of the event to the resale of the ticket at a higher price was obtained in writing in advance; and
2. the resale is carried out in accordance with the agreement entered into with the producer of the event and, if applicable, the promoter of the event.

Bill 10 will also require the producer of an event to inform the authorized vendor and, where applicable, the reseller with whom the producer has entered into an agreement, of the cancellation of the event or any change to its schedule or location²⁷. Consumers must be notified of this information by the vendor or reseller as soon as possible²⁸.

Rather than prohibiting fees for the transfer of event tickets, as the initial version of the bill would have done²⁹, the legislation adopted by the National Assembly requires a breakdown of the amounts making up the total ticket price³⁰. The breakdown must clearly indicate the face value of the ticket as set when it was issued, as well as the nature of all fees charged³¹. This requirement does not relieve merchants of their obligation to display the total price more prominently than its component amounts³².

Importantly, Bill 10 establishes a presumption whereby any person who enables a third party, by technological means, to resell a ticket and collect payment is deemed to resell the ticket, require payment of its price, or facilitate its resale, and must ensure that the third party possesses or controls the ticket³³.

Legal risks

The amendments made to the CPA by Bill 10 will strengthen the legislative framework applicable to online subscriptions and ticket resale. Businesses may face increased risks of administrative investigations, penalties, civil proceedings, and class actions when the new provisions come into force, particularly those requiring information to be presented “clearly,” as this concept remains open to interpretation.

More specifically, businesses should review their digital interfaces, subscription cancellation processes, communications relating to free or promotional periods, price and non-recurring fee display practices, and their terms and conditions governing consumer reviews. Ticket resale platforms should review their disclosure mechanisms, price breakdowns, and procedures for communicating information regarding event cancellations or changes to event schedules or locations.