Washington – In comments filed with the Québec government, the Computer & Communications Industry Association warned that Québec’s Bill 109, the Act respecting the discoverability of French-language cultural content, would create significant digital trade barriers for U.S. streaming platforms and device manufacturers, impose duplicative regulations, and conflict with Canada’s USMCA trade obligations.
The comments respond to a public consultation on Bill 109, which was introduced in May 2025. The bill seeks to promote French-language cultural content by mandating French-by-default interfaces, imposing content quotas and “discoverability” rules, and establishing “must-carry” rules for services the Quebec government seeks to promote through government-designated apps on connected devices. For more background on Bill 109, see CCIA’s two-pager in English and French.
CCIA’s filing highlights that the bill constitutes de facto discrimination under the USMCA, as previous CCIA analysis shows 80 percent of captured services are U.S.-based, and all non-French content (which they would naturally carry) would be de-prioritized or, in case of quotas, possibly reduced. The filing also notes that Bill 109 risks duplicating Canada’s federal Online Streaming Act (formerly known as Bill C-11), which separately is estimated to cost the U.S. music and film industry up to $7 billion by 2030. Bill 109 would force companies to navigate two potentially conflicting compliance regimes for a single market (e.g., discoverability mandates based on language vs “CanCon”). Additionally, Bill 109 imposes high compliance costs from technically impractical quotas, forced algorithmic redesigns, and new inspection regimes, which would fragment the North American market.
The following can be attributed to CCIA Vice President of Digital Trade, Jonathan McHale:
“Québec has had a longstanding and legitimate goal of promoting the use of the French language in its region. But transitioning from voluntary promotion to regulatory mandates in the digital realm is a decision fraught with unintended consequences that could backfire, suppressing the creation and distribution of quality French-language content. It would also seriously undermine U.S. firms’ ability to operate in Quebec.
“This bill would fragment the North American digital market, create a duplicative and uncertain regulatory environment, and it appears to be in conflict with Canada’s USMCA commitments. We urge Québec to reconsider this approach and work with stakeholders on measures that support cultural goals without discriminating against digital services or undermining the integrated continental market.”
