Quebec Regulators Can Now Order Deepfake Ads Offline

By Julius Melnitzer | August 19, 2026

The Bill confers a new power to issue orders usually reserved for courts of law, allowing the regulator to intervene at any time before a ruling and order the cessation of a representation falsely linked to an individual, in accordance with the principles of procedural fairness. — Thomas Chagnon

A new Quebec law lets the province’s consumer and financial watchdogs order the removal of fraudulent online advertising without resorting to the courts – and it reaches the businesses that host or pass along the content.

The scenario has become ubiquitous: a video of a public figure such as a celebrity, athlete or businessperson appears in social media endorsing cryptocurrency platforms, anti-wrinkle creams, so-called diabetes cures or weight-loss products. But the endorsement is fake: the face and voice were AI-generated.

Cheap generative AI tools have made these fakes convincing and fast to produce. Quebec has responded with a statute aimed squarely at them.

“These scams create two categories of victims,” says Thomas Chagnon, a Montreal-based intellectual property lawyer in the emerging technologies group at ROBIC, a member of the IPH network. “There are the public figures whose images, voices and reputations are misused to deceive consumers, and there are the consumers themselves, who are misled because they trusted those public figures.”

What the law does

Bill 24, the Act Protecting Consumers Against the Deceptive or Fraudulent Use of a Person’s Identity or Image, was introduced by Justice Minister Simon Jolin-Barrette on March 26, 2026 and came into force on June 12. It amends Quebec’s Consumer Protection Act (CPA) and the regulation governing monetary administrative penalties (AMPs) under that statute.

The core prohibition, a new section 238.1, bars using – or allowing the use of – a person’s identity or image to make a representation to a consumer without that person’s consent. A person’s “image” is defined broadly enough to capture any image, altered or not, that represents or appears to represent someone, as well as any visual or sound recording of that person.

The legislation also does not allow anyone to “tolerate” such use. “Passively witnessing such a representation is prohibited,” Chagnon says. “So the prohibition against tolerating any offending conduct warrants particular attention from businesses that distribute or host content that may violate section 238.1.”

New regulatory powers

Previously, the Office de la protection du consommateur (OPC), Quebec’s consumer protection regulator, could investigate, prosecute and impose AMPs on CPA offenders, but it could not stop anyone from continuing to run impugned deepfakes: that required court intervention.

Bill 24, however, gives the OPC president and – where financial-sector legislation is involved – the president and chief executive officer of the Autorité des marchés financiers (AMF), the province’s financial sector regulator, power to impose stop orders directly.

“The Bill confers a new power to issue orders usually reserved for courts of law,” Chagnon says. “The president may intervene at any time before a ruling and order the cessation of a representation falsely linked to an individual, in accordance with the principles of procedural fairness.”

That covers representations falsely claiming certification, recommendation, sponsorship, approval or affiliation with a third party, and representations falsely claiming that a third party endorses a product.

Both a person whose identity was taken and a deceived consumer can complain to the OPC. The regulator can also order the preservation of evidence relating to a breach of the Act’s business practices provisions as well as the destruction of the offending video or image. The latter power echoes separate provincial legislation targeting the non-consensual sharing of intimate images.

Penalties

The legislation provides for quasi-criminal penalties (when the OPC decides to prosecute in court) or AMPs, imposed directly by the regulator. Quasi-criminal fines can reach $62,500 for an individual and $125,000 for a business, or five per cent of worldwide revenue in certain cases. Companies selling the impugned products or services as well as companies running or hosting the advertisements can face quasi-criminal proceedings.

Failing to comply with a cessation order can lead to contempt charges before the Superior Court, which carry the possibility of imprisonment.

How victims benefit

The conventional route—court proceedings against an often anonymous, frequently offshore advertiser—is slow and expensive, and the advertisement keeps running while the court proceedings play out.

“The new power to issue orders should accelerate efforts to stop, or even eliminate, the dissemination of images used without consent, while limiting the number of collateral victims of advertisements falsely linked to public figures. The penalties adopted should also make it easier to support victims and deter fraudsters,” Chagnon says.

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