Yes. If your fintech handles personal information on Quebec residents, whether you're headquartered in Montreal or just processing payments for customers there, Law 25 applies to you, and the penalties (up to 4% of worldwide turnover or $25 million CAD) are the steepest privacy fines in Canada.
What Quebec Law 25 Actually Requires of Fintech Companies
Law 25 (formerly Bill 64) rewrote Quebec's private-sector privacy law in three phases between 2022 and 2024, and it borrows heavily from GDPR while adding its own Quebec-specific teeth. For a fintech, the obligations that matter most are:
- A named privacy officer, by default the most senior executive in the company unless you designate someone else in writing.
- Mandatory Privacy Impact Assessments (PIAs) before launching any new product, feature, or third-party integration that touches personal information, including new payment rails, KYC vendors, or fraud-scoring models.
- A 72-hour-equivalent breach notification duty to Quebec's regulator (the CAI) and to affected individuals when there is a "risk of serious injury."
- Data portability and a right to de-indexing that most legacy fintech data architectures were never built to support.
- Consent standards that are explicit, granular, and revocable, a much higher bar than the implied consent many fintech onboarding flows still rely on.
None of this is theoretical for a company moving money. Payment processors, lenders, and neobanks collect exactly the categories of information Law 25 treats as highest-risk: financial account numbers, transaction histories, credit data, and government ID used for KYC.
Why Fintech Carries More Law 25 Exposure Than Most Sectors
Quebec's regulator has made clear it is not waiting for a marquee breach to start enforcing. Fintech sits in the crosshairs for a few structural reasons. First, the data itself is higher-stakes: a leaked transaction history or credit profile causes more concrete harm than a leaked email list, which raises the "risk of serious injury" threshold that triggers mandatory notification. Second, fintechs typically run on a stack of third-party processors, KYC vendors, card networks, and cloud infrastructure providers, and Law 25 makes you accountable for what happens to personal information after you hand it to a subcontractor. A data-sharing agreement that was fine under PIPEDA may not meet Law 25's stricter contractual requirements for cross-border transfers.
Third, fintechs expanding from Ontario or out of the US into Quebec often assume a national PIPEDA compliance posture is enough. It isn't. Quebec's law is materially stricter, and the CAI has independent enforcement authority with fines that dwarf what the federal Privacy Commissioner can levy.
The Automated Decision-Making Clause
One provision that catches fintechs specifically: Law 25 requires you to inform individuals when a decision is made exclusively through automated processing, and to explain the factors that led to that decision on request. Credit scoring models, fraud flags, and algorithmic loan approvals all fall under this. If your underwriting or fraud detection runs on a model with no human review step, you need a documented process for explaining outcomes, not just a compliant privacy policy.
Sector Stakes: Why This Is Not Optional for Payments and Lending
Beyond the direct fines, Law 25 non-compliance creates downstream problems that hit revenue faster than a regulatory notice does:
- Enterprise and bank partners increasingly require proof of Law 25 compliance in vendor due diligence before signing, alongside SOC 2.
- Payment network and sponsor bank agreements often reference applicable privacy law compliance as a contractual condition, and a CAI finding can trigger a review of that relationship.
- Class action exposure has grown in Quebec since Law 25 created a private right of action tied to certain breaches, on top of regulatory fines.
- Investors doing diligence on Series A and B fintechs are starting to ask for Law 25 documentation specifically, not just a generic privacy policy, because it signals operational maturity.
For a fintech trying to close deals with Quebec-based enterprise clients or expand into the province at all, Law 25 compliance stops being a legal checkbox and becomes a sales enablement asset.
How traztech Scopes a Law 25 Engagement for Fintech Clients
We treat Law 25 as a distinct, narrow scope rather than folding it into a generic privacy audit, because fintech data flows are specific and the regulator's expectations are specific. A typical engagement runs in four stages:
- Data mapping. We trace every place personal information enters, moves through, and leaves your systems, including payment processors, KYC providers, and any US-based cloud infrastructure, since cross-border transfer is a distinct risk area under the law.
- Gap assessment against the three phases. We check your privacy officer designation, incident response plan, consent flows, and existing PIAs against what the CAI actually expects to see in an investigation, not just the statutory text.
- Automated decision documentation. For any credit, fraud, or risk model running without human review, we build the disclosure and explainability documentation the law requires.
- Remediation and evidence package. We close the gaps that matter most given your risk profile and leave you with a defensible compliance file, the kind you can hand to a bank partner, an investor, or the CAI itself if asked.
Because Law 25 is a niche, high-stakes vertical rather than a broad market, we can go deep fast. Our team, led by Jacob Masse, brings a security researcher's read on how these systems actually fail, not just a checklist read on what the statute says. Full detail on how we approach the framework is on our Quebec Law 25 framework page.
Quebec Law 25 in the Broader Canadian Privacy Picture
Law 25 doesn't replace PIPEDA, it sits alongside it and, in most respects, exceeds it. Fintechs serving customers across Toronto, Waterloo, Ottawa, Vancouver, Calgary, and Montreal need a compliance posture that satisfies both the federal baseline and Quebec's stricter regime wherever Quebec residents are in the customer base. We built our Canadian Privacy and Cybersecurity Compliance (CPCSC) approach around exactly this layering problem, so fintechs don't have to run separate, conflicting compliance tracks for each province they operate in. It's also the reason Law 25 work pairs naturally with our broader compliance advisory engagements for companies building toward SOC 2 or preparing for US market entry.
Getting Started
If your fintech is processing Quebec residents' personal or financial information and you haven't run a Law 25 gap assessment, the exposure is already live, the phased deadlines have passed. Book a scoping call through our contact page and we'll tell you plainly whether you have a real gap or a paperwork problem, before a regulator or a bank partner asks first.