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ARTICLE · 18 JUNE 2018

Update To Québec's Proposed Loyalty Program Rules

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​In our previous bulletin Ontario and Québec Set to Update Legal Requirements on Loyalty Programs, we highlighted the recent legislative changes regarding loyalty/rewards programs ...

CanadaCorporate/Commercial Law
Alexandra Nicol
Alexandra Nicol
Vinay Desai
Vinay Desai
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In our previous bulletin Ontario and Québec Set to Update Legal Requirements on Loyalty Programs, we highlighted the recent legislative changes regarding loyalty/rewards programs that have been implemented in Ontario and confirmed in Québec. Ontario's rules on loyalty programs and associated regulations came into force on January 1, 2018, with a retroactive effect to October 1, 2016. The significant detail of the Ontario rules is that they prohibit rewards points from expiring due to the passage of time alone. However, the Ontario rules provide an exception permitting the expiry of rewards points due to account inactivity.

Québec

Québec adopted similar rules regarding loyalty programs in November 2017, but which are not yet in force. On April 18, 2018, Québec introduced draft associated regulations (the "Regulations") providing for certain exemptions from the general rule prohibiting the expiry of rewards points, as well as further specifications regarding

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