The essentials: since October 1, 2025, every Quebec employer must identify, analyze and prevent psychosocial risks on the same footing as physical risks. The required mechanisms — a prevention program (20 workers or more) or an action plan (19 or fewer) — must be in place by October 1, 2026.
What is Law 27 (LMRSST)?
The Act to modernize the occupational health and safety regime (S.Q. 2021, c. 27), known as “Law 27,” is Quebec’s biggest occupational health and safety reform in 40 years. Its central change: psychological health is now protected on the same footing as physical health. The Regulation respecting prevention and participation mechanisms in establishments, in force since October 1, 2025, makes these obligations concrete for every employer — regardless of size or sector, starting from a single worker.
What is a psychosocial risk at work?
A psychosocial risk is a factor tied to work organization or social relations that can harm people’s psychological health. The CNESST identifies, among others:
- excessive workload and chronic stress;
- low decision latitude (little control over how one works);
- lack of recognition and effort-reward imbalance;
- weak social support from colleagues or managers;
- organizational injustice (decisions perceived as arbitrary);
- psychological or sexual harassment and workplace violence, including domestic or family violence that manifests at work.
Law 27 puts them on the same footing as physical risks: they must be identified, analyzed, documented and controlled — not just “taken seriously.”
What the law requires, by organization size
20 workers or more: the prevention program
- Identify and analyze the risks — physical AND psychosocial — in each establishment.
- Produce a written prevention program with measures, owners and timelines, kept up to date.
- Set up a joint health and safety committee (HSC) that meets periodically.
- Designate a health and safety representative from among the workers.
- Provide training for committee members and the representative.
19 workers or fewer: the action plan
- Identify the risks present in the workplace.
- Produce a written action plan: concrete measures, without the weight of the full program.
- Designate a health and safety liaison officer from among the workers.
In both cases: the approach must be written, involve worker participation, cover psychosocial risks, and be kept alive — the CNESST expects periodic follow-up, not a one-time filing.
Key dates
- 2021 — Law 27 is adopted. Post-traumatic stress disorder (PTSD) becomes the first psychological condition with a presumption under the Regulation respecting occupational diseases: under the prescribed conditions, the worker no longer has to prove the link with work.
- October 1, 2025 — The permanent regime takes effect: prevention obligations, including psychosocial risks, apply to all employers.
- October 1, 2026 — Deadline to have the mechanisms in place: prevention program or action plan, health and safety committee or liaison officer, depending on your size.
What do you risk if you don’t comply?
Three levels of consequences, from the most visible to the most expensive:
- Direct sanctions. The CNESST can issue correction notices and statements of offence. Fines under the OHS Act start at roughly $1,500 to $3,000 for a first general offence, double then quadruple for repeat offences, and reach six figures for the most serious ones.
- Rising premiums. Your personalized CNESST rate follows your claims history. Every preventable claim lands on your bill — year after year.
- The claims themselves. That’s the real cost. According to CNESST statistics, average payouts for a harassment-related injury reached $54,362 in 2024. And with the PTSD presumption, the burden of proof has shifted toward the employer for traumatic events.
The numbers that show the risk is real
Work injuries attributable to psychosocial risks rose 71.4% between 2020 and 2024 in Quebec (CNESST, Statistics on work-related psychosocial risks 2020-2024).
Complaints for psychological or sexual harassment under the Act respecting labour standards reached 6,817 in 2024, up 54.1% in five years (CNESST, same source).
Average payout for a harassment-related injury in 2024: $54,362, up 45.7% since 2020 (CNESST, same source).
In other words: the question isn’t “will the CNESST knock on my door?” but “how much will the first claim I failed to prevent cost me?”
The most common trap: the “once and for all” exercise
Most organizations produce a document, file it, and move on. But the law requires a continuous approach: identify, correct, reassess, document — and be able to demonstrate it. During an inspection or a claim, the CNESST won’t ask whether you have a document; it will ask for your analyses, your measures, your follow-ups and their dates. A frozen 2025 plan won’t meet that bar in 2027.
That’s exactly the problem Strategenia exists for: psychosocial-risk compliance isn’t a deliverable, it’s a continuous improvement loop — like the rest of organizational health.
Where to start: 5 steps
- Establish your threshold. Count workers per establishment: 20 or more = prevention program + committee + representative; 19 or fewer = action plan + liaison officer.
- Identify psychosocial risks with your workers, not for them. Participation is a legal requirement — and your people know where it hurts. A short anonymous survey plus a structured team discussion.
- Prioritize by severity and frequency. Not everything gets fixed at once. Two or three risks handled well beat a list of twenty good intentions.
- Document measures, owners and timelines in writing. That document — program or plan — is what the CNESST will want to see, along with its updates.
- Schedule the next cycle before closing this one. Reassess every 6 to 12 months, inside your existing management meetings. That’s what separates a living practice from a dead binder.
Frequently asked questions about Law 27
Who does Law 27 apply to in Quebec?
Every employer with at least one worker in Quebec, regardless of size or sector. Only the scale and form of the mechanisms vary, depending on whether the establishment has 20 workers or more, or 19 or fewer.
What is the compliance deadline?
The obligations have applied since October 1, 2025, and the prevention mechanisms — prevention program or action plan, health and safety committee or liaison officer — must be in place no later than October 1, 2026.
What’s the difference between a prevention program and an action plan?
The prevention program (20 workers or more) requires identifying AND analyzing risks, with a joint health and safety committee, a designated representative, and training. The action plan (19 or fewer) is a lighter version: risk identification, written measures and a liaison officer, without a mandatory committee.
Do psychosocial risks cover remote work?
Yes. The modernized act expressly applies to teleworking employees. Overload, isolation, hyperconnectivity and the work-life boundary are among the risks to consider, wherever the work is performed.
What are the fines for non-compliance?
Fines under the OHS Act start around $1,500 to $3,000 for a first general offence and rise sharply for repeat or serious offences. But the real cost is elsewhere: higher personalized CNESST premiums, and claims whose average payouts exceed $50,000 for harassment-related injuries.
Is a one-time document enough?
No. The law requires a continuous approach: identification, measures, reassessment and documented updates. During an inspection or a claim, the CNESST examines the history of your practice, not the existence of a document.
Strategenia integrates psychosocial risks into the full picture of your organization — 13 domains, 63 cells — and keeps your prevention practice alive from one cycle to the next. See the Law 27 approach or join the beta.
