Quebec’s Order in Council O.C. 1338-2026 establishes the coming-into-force dates for provisions of the Act mainly to reduce the administrative burden of physicians (2024, chapter 29). The order is intended to provide a staged implementation of legislative changes aimed at reducing administrative requirements affecting physicians while coordinating those changes with amendments to the Act to promote access to family medicine and specialized medicine services.

The regulation primarily changes when different sections of the 2024 legislation become legally effective. Section 11 of the Act mainly to reduce the administrative burden of physicians provides that its provisions come into force on dates determined by the government, subject to specific exceptions.

This includes sections 1 and 2, section 4 insofar as it does not concern specified provisions of the Act to promote access to family medicine and specialized medicine services, and section 5 of the 2024 Act. Section 4 requires more detailed treatment because it introduces several provisions into the Act to promote access to family medicine and specialized medicine services. In particular, section 4 creates section 29.1 and related provisions, including sections 29.5, 29.9, 29.10, 29.12 and 29.15 insofar as they relate to section 29.1.

Another provision, section 29.3 of the Act to promote access to family medicine and specialized medicine services, is subject to a separate timetable. This establishes the second major implementation phase and gives government and affected stakeholders additional time to prepare for the requirements associated with section 29.3.

The order therefore creates a phased implementation framework rather than bringing the entire physician administrative-burden legislation into force simultaneously. January 1, 2027 serves as the principal starting date for the legislation, while December 1, 2027 is reserved for the delayed implementation of section 29.3. The provisions tied to section 29.1 remain dependent on a future regulation.

The key takeaway is that O.C. 1338-2026 is primarily an implementation order, not a substantive rewriting of the physician-burden legislation. The aim is to reduce physicians’ administrative burden by limiting unnecessary insurer and third-party demands. Sections 1, 2 and 5 mainly reorganize the legislation and do not create significant new duties for doctors. Section 4 is the key change, limiting insurer-required medical services and examination schedules, restricting the health information third parties can request, and allowing standardized forms.

Quebec (1338/2026) September 8, 2026
Disclaimer: Insights are for informational purposes only and does not reflect RRI’s official position or constitute legal opinion.