Quebec raises minimum environmental fines up to tenfold for high-impact industries

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Companies in several high-impact industrial sectors in Quebec could now face minimum environmental fines of as much as $300,000 per day under changes to the province’s Environment Quality Act (EQA).

Effective August 13, 2026, the changes increase minimum fines by up to tenfold for certain environmental offences committed by organizations carrying out prescribed industrial activities.

According to Quebec’s Ministry of the Environment, the tougher penalties are intended to strengthen deterrence and encourage companies to invest more heavily in environmental compliance and risk prevention.

Among the affected sectors are mining, petroleum refining, pulp and paper, battery operations, aluminum smelting, foundries and cement manufacturing.

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Under the amendments, the minimum fine for failing to comply with a standard or condition of a ministerial authorization rises from $7,500 to $75,000 per day.

Carrying out an activity without a required ministerial authorization can now result in a minimum fine of $150,000 per day, up from $15,000.

For the release of contaminants into the environment, the minimum fine increases from $30,000 to $300,000 per day.

The higher penalties were established through a new section of the EQA that increases mandatory minimum fines for certain offences involving prescribed industrial activities.

Changes to the Regulation respecting the regulatory framework applicable to activities based on their environmental impact (REAFIE) identify which activities are subject to the enhanced fines and establish applicable thresholds. Only organizations whose activities are covered under the new section 14.1 of the regulation are subject to the higher mandatory minimums.

In addition to battery operations, petroleum refineries, pulp and paper facilities and mines, affected industries can include iron, steel and ferroalloy manufacturing; quicklime and hydrated lime manufacturing; and the production of chemical products, explosives and glass.

The changes significantly increase the potential financial consequences of environmental violations for companies operating in those sectors.

The targeted offences are considered strict liability offences, meaning an organization accused of a violation may be able to rely on a due diligence defence. Companies may therefore need to demonstrate that they took reasonable measures to prevent the offence from occurring.

Organizations operating in affected sectors are being advised to determine whether their facilities and activities fall within the new regulatory provisions and to review their environmental compliance and risk-management programs in light of the substantially higher penalties.

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