Quebec harassment policy training: what the Act asks of you

What does Quebec law say about harassment policy training?

The policy must set out the specific information and training programs on preventing psychological harassment that are offered to employees, and to the persons the employer designates to manage a complaint or report (Act respecting labour standards, s. 81.19). That is two audiences, and a policy that names the programs for each.

Section 81.19 gives no number of hours, no frequency and no format. It does set the standard the training sits inside: the employer must take reasonable action to prevent psychological harassment from any person and, once aware of such behaviour, to put a stop to it. CNESST lists training staff among the preventive measures an employer can use, next to regular reminders of the measures in place.

What else must the policy contain, and since when?

At least seven things. The policy must set out the methods used to identify, control and eliminate harassment risks, including a section on conduct of a sexual nature; the training programs; recommendations on conduct at work-related social activities; how to make a complaint or report, who is designated to manage it and what follow-up the employer owes; the measures that protect the people involved and those who cooperated; the process for managing a situation, any inquiry included; and confidentiality, with documents kept for at least two years.

Bill 42 received assent on 27 March 2024 (S.Q. 2024, c. 4). Its provisions took effect that day, except some, among them the list of what the policy must set out, which took effect on 27 September 2024. The Bill also added the harassment policy to the contents of the prevention program and the action plan under the Act respecting occupational health and safety, and CNESST's drafting guide says the policy must be an integral part of that program or plan from 1 October 2025.

The program (s. 59) and the plan (s. 61.2) are provisions that Loi 27 (S.Q. 2021, c. 27) enacted or amended, and OHA's page on Loi 27 sets out that wider law in one screen. A policy written before September 2024 deserves a point-by-point re-read against the seven items.

Who should be trained, and on what?

The Act names employees and the designated persons. CNESST's examples of roles add two more groups. In those examples, managers and team leads spot risk factors with their team and step in informally on situations at risk. HR advises and trains staff on harassment prevention and on applying the policy, or makes sure managers receive that training, and trains the people who act as mediators or investigators, or makes sure they are trained, as the employer chooses when drafting the policy.

For the designated persons, CNESST recommends people whose credibility and independence are established, more than one where the size of the organization allows it, and training in how to assess a situation and intervene when a complaint or report arrives.

For everyone else, CNESST's examples of measures include training staff on incivility and on psychological, sexual and discriminatory harassment, putting the subject into the onboarding of new hires, reminding workers of the measures in place, checking that policies and procedures are applied and understood, and reviewing the policy every year. What gets taught starts from the Act's definition: repeated, hostile or unwanted conduct that affects a person's dignity or psychological or physical integrity and results in a harmful work environment; a single serious incident with a lasting harmful effect may also count (s. 81.18).

What happens when someone files a complaint?

An employee can file a complaint with CNESST within two years of the last incident of the behaviour (ss. 123.6 and 123.7); employees covered by a collective agreement use the recourses the agreement provides (s. 81.20). If the Administrative Labour Tribunal finds psychological harassment and that the employer failed the duties in section 81.19, it may render any decision it believes fair and reasonable, such as reinstatement, an indemnity up to the wages lost, moral or punitive damages, or payment for psychological support (s. 123.15).

A breach of section 81.19 also carries a fine of $1,000 to $25,000 for a natural person and $2,000 to $50,000 in any other case (s. 140.1). And section 122 bars reprisals against an employee who reported harassment targeting another person or who cooperated in processing a report or complaint. That last point belongs in what managers are taught, because a report can reach a manager first.

The volume is rising. CNESST reports 7,848 complaints filed in 2025 for psychological or sexual harassment under the Act respecting labour standards, up from 4,398 in 2021, an increase of 78.4% in five years. The figures count complaints filed, not cases where harassment was found.

Where does a manager's capacity come in?

Training covers what to do; capacity decides whether the people named in the policy can do it in the week they actually have. Receiving a report, meeting the people involved, protecting confidentiality and keeping the documents for at least two years all land on a job that already existed.

In OHA's Five Loads framework, that work weighs on several loads at once: emotional load, when a person absorbs other people's stress; relational load, when everything runs through one person; decisional load, when the consequences of a decision weigh heavily; and administrative load, when every step has to be recorded. It is a way to read the designated person's week next to what the law asks of the policy.

CNESST asks for a process to identify the risk of harassment and lists, among the means, consulting staff on the work climate through interviews or questionnaires. Our post on how to spot psychosocial hazards shows where to look. The check below takes about a minute and uses five of the ten statements in OHA's capacity self-portrait, one for each of the Five Loads. Answer for a designated person, or for yourself.

What can an HR lead do in the next 90 days?

Five moves, in this order. Re-read the policy against the seven items, the training clause above all. Write down the names or functions of the designated persons, and of at least one back-up, then note what training each has received. Put the subject into onboarding and set the date of the yearly review that CNESST recommends among its follow-up measures. Give managers a short briefing on reprisals and on what to do with a report. Finally, read the load of the people who receive reports before the training and again 90 days later, with the same statements.

The second reading answers a question an attendance list cannot: did the training leave the people who carry the policy with more room, or with one more load? An unchanged result is information too. It tells you the training did not change their load.