The Order in Council 577-2025, dated April 23, 2025, introduces amendments to the Regulation respecting labour standards under the Act respecting labour standards (chapter N-1.1). The core of the amendment addresses the employment of children under the age of 14, a matter governed by section 84.3 of the Act. This section prohibits employers from having work performed by children under 14 years old, unless specific exceptions are established by government regulation. The regulatory amendment is made under the authority granted by section 89.1, which allows the Government of Québec, after consultation with the Commission des normes, de l’équité, de la santé et de la sécurité du travail (CNESST), to set out the conditions and situations under which the general prohibition does not apply. Moreover, section 91 allows such standards to vary by type of work or field of activity, enabling tailored exemptions that reflect the realities of different sectors.

The regulation specifically amends section 35.0.3 of the existing Regulation respecting labour standards. It replaces subparagraph 7 of the first paragraph and adds a new subparagraph 7.1. The revised subparagraph 7 now clarifies that a child under the age of 14 may work for a non-profit sports organization, or for a municipal or intermunicipal entity, in a supportive capacity during sports activities. This includes roles such as assistant instructor, assistant coach, or scorekeeper. The language underscores the non-commercial and supportive nature of such work, suggesting that these roles are developmental or voluntary in character and not exploitative.

Subparagraph 7.1 introduces a new exemption, allowing children to work for municipalities, metropolitan communities, or intermunicipal management boards in recreational activities such as day camps or vacation camps. This addition recognizes the long-standing practice of involving youth in community-based recreational programming, and formalizes it as a lawful exception to the general prohibition on child labour under the age of 14. It also reflects a policy aim of balancing child protection with the promotion of civic engagement and community involvement among young people.

The regulation’s amendments aim to modernize and clarify the scope of permissible child involvement in structured, low-risk environments, emphasizing mentorship and learning experiences rather than commercial labour. These exceptions reinforce the government’s broader approach to regulating youth employment by distinguishing between exploitative work and community-based engagement opportunities. Furthermore, these amendments are aligned with public expectations and social norms regarding appropriate roles for children in organized activities and support the viability of local recreation programs that depend on youth participation.

The legal enactment is intended to refine the Government of Québec’s labour standards framework to better reflect the province’s social landscape while maintaining safeguards for young workers.

Quebec (577-2025) May 7, 2025
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