New Ownership Transparency Requirements For Corporations Operating In Quebec

Effective March 31, 2023, new ownership transparency requirements for enterprises conducting a business in Quebec will come into effect as a result of the recently passed Bill 78 entitled An Act Mainly to Improve the Transparency of Enterprises ("Bill 78"), thereby amending, inter alia, the Act Respecting the Legal Publicity of Enterprises (the "Act"). Businesses should take steps prior to the March 31, 2023 implementation date to gather the information required when preparing their Annual Updating Declaration.

All businesses to which the Act applies will have to follow the new obligations introduced by Bill 78. However, some enterprises will be exempted from the obligation to declare their ultimate beneficiaries to the Quebec Enterprise Registrar (the "QER"), including but not limited to the following: