Law 27: One Month Left to Finalize Your Psychosocial Risk Prevention Program

The good news is that this is not an impossible task. The less good news is that, after this date, the period granted to prepare this document officially comes to an end. Organizations that have not completed their prevention program or action plan may face very real consequences.

The Official Countdown

Since October 1, 2025, the permanent regime provided for under the Act to modernize the occupational health and safety regime (LMRSST, commonly referred to as Law 27) has been fully in effect for all employers covered by the legislation. This includes the occupational health and safety committee, the health and safety representative, the liaison officer, the prevention program or action plan, and the integration of psychosocial risks (PSRs), among other requirements.

However, the legislator provided employers that did not already have a prevention program with a one-year period to develop and implement either a prevention program (20 workers or more) or an action plan (19 workers or fewer), incorporating PSRs in the same way as chemical, physical and ergonomic risks. Please note that employers that already had a prevention program are not entitled to this one-year grace period to prepare an action plan.

This one-year period applies only to the preparation of the document, whether it is a prevention program or an action plan. It ends on October 1, 2026, and there is no general or sector-specific extension after that date. The occupational health and safety committee, liaison officer and health and safety representative, on the other hand, were required to be in place as of October 1, 2025, with no grace period.

What Can Happen If the File Is Not Completed on Time

It is sometimes forgotten that a CNESST inspection does not require a serious accident to be initiated. A complaint from a staff member, a targeted sectoral context or simply a follow-up visit may be sufficient.

In practice, the process works as follows:

1. Non-compliant inspection. The inspection identifies the absence or inadequacy of the prevention program or action plan, or the failure to integrate PSRs into the document.
2. Possible offence notice. The CNESST may initiate penal proceedings under sections 236 and 237 of the Act respecting occupational health and safety (AOHS). These are strict-liability offences: it is sufficient to demonstrate that a violation occurred; intent does not need to be proven.
3. Fine, where applicable. The amounts established by the CNESST^[1] are indexed every January 1 and vary according to the seriousness of the violation and whether there has been a repeat offence. For a company, as a first offence, the fine ranges from $2,115 to $4,226 for an administrative violation, such as the absence of an action plan or prevention program. It ranges from $21,127 to $84,519 if the violation directly and seriously compromises the health or safety of personnel. In the event of an additional repeat offence, these amounts can rise to $16,904 and $422,596 respectively.

This is not an amount that will place a company in jeopardy after a first offence. However, the consequences are more significant than they may initially appear and escalate quickly in the event of a repeat offence: closer inspection follow-up, a potential impact on CNESST assessments, and, sometimes, a difficult conversation with a board of directors or other stakeholders.

The Six Psychosocial Risk Factors to Address in Your Program

To avoid uncertainty about what needs to be documented, here are the factors that the legislation requires employers to identify and analyze, in addition to the risks of harassment and violence that are already covered:

• Workload: realistic objectives, management of interruptions and clear priorities
• Recognition: regular feedback, perceived fairness and appreciation of efforts
• Decision-making autonomy: room for manoeuvre and participation in decisions that affect the work
• Supervisor support: management’s ability to listen and availability, as well as support when difficulties arise
• Coworker support: mutual assistance, collaboration and the quality of relationships between peers
• Information, communication and organizational justice: clarity and flow of information, consistency and transparency of decisions, and fair treatment

These factors must be analyzed as a whole, rather than in isolation. Our approach includes 12 indicators that provide an overall view of the situation and support the development of concrete recommendations.

What Remains to Be Done Before October 1, 2026

Reminder: the participation structures (the occupational health and safety committee, liaison officer and health and safety representative) were required to be in place as of October 1, 2025.

What remains to be finalized by October 1, 2026, is the written document: involve the right people, identify the risks using an appropriate tool, such as the INSPQ grid, prioritize them, document a dated and signed action plan or prevention program, and then implement it.

Conclusion

One month is enough to structure a serious process, provided you do not wait until the last minute. The benefits also go well beyond compliance: a well-designed PSR prevention program can contribute to lower absenteeism, improved retention and a healthier workplace climate over the long term.

Want to go further? Structure your PSR compliance process before the deadline with our Organizational Health support, including a diagnosis, a prioritized action plan and compliance follow-up tailored to the size and budget of your organization.

1. CNESST Framework for Issuing Offence Notices, March 2026 ↑