2026 Elections: What the Election Act Prohibits for Your Union When the Campaign Starts

Since January 1, 2026, Quebec has been in a pre-election period. Any partisan paid advertising by a third party, including a union, must be declared to Élections Québec as soon as it exceeds $1,000 in design, production or distribution costs. No spending cap applies at this stage — only the obligation to declare.

Your Union Is a Third Party Under the Election Act

The Election Act classifies unions as third parties, on the same footing as businesses, organizations and citizens who are not candidates. The real regime change occurs at the official start of the campaign, not before.

The 2026 Electoral Calendar: Key Dates

The vote is set for October 5, 2026. Élections Québec projects the campaign launch for August 29. The election period lasts between 33 and 39 days. Key dates to plan your communications around:

September 16: deadline to register to vote outside Quebec
September 23: leaders' debate, broadcast on Radio-Canada
September 25 to October 1: advance voting period
October 5: election day, election of 127 MNAs to the National Assembly

What Becomes Prohibited When the Campaign Starts

Once the campaign launches, third parties can generally no longer incur expenses that could favour or disfavour a party. A paid Facebook ad, a video produced for social media that involves filming or editing costs — both fall under this regime. An organic, unpaid post remains permitted.

Certain activities remain permitted throughout the campaign: publishing opinion articles or letters, public assemblies related to the organization's regular mission, and social media posts as long as no money is paid to boost their reach. Élections Québec also allows the distribution of political platform comparisons, provided they present all parties equitably, without commentary or preferential treatment.

Sending a voter reminder or neutral information through an app your union already owns creates no media buy — and therefore no new electoral expense to declare.

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The "Particular Intervenor" Status Is Not Available to Your Union

There is a particular intervenor status that allows an individual voter to spend up to $300 on non-partisan advertising on a public issue. This status is reserved for natural persons. A union, corporation or association cannot obtain it, regardless of its size. The legal avenue of paid advertising is therefore closed to union organizations during the campaign.

What Your Union Risks for Non-Compliance

The fines are not symbolic. For a legal person, they can reach $50,000. Élections Québec interprets the notion of electoral expense broadly: a website, a mobile app, an event — anything that gives visibility to a party can be targeted, even if the intent behind it is neutral. Élections Québec states that it favours information over sanctions when irregularities are detected, but recommends consulting its guides before acting when in doubt. Several federations, including the CSQ, reminded their affiliated unions this year to validate any activity involving a cost with their legal services before the campaign launch.

What You Can Always Share Without Creating an Electoral Expense

The law never prohibits distributing factual, non-partisan information to your members at no production cost. In practice, that includes:

A voter list registration reminder. Élections Québec estimates that more than 400,000 eligible voters in Quebec are not on the list — roughly 6% of the electorate
Advance voting dates, from September 25 to October 1
A member's polling station address on election day
A fair comparison of all parties' commitments on an issue affecting your members, without favouring any one of them

Published on a channel you already own, with no media buy, none of this content creates a new electoral expense to declare.

Fortisia sends your voter reminders and neutral communications as push notifications, without going through an external ad purchase.

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Why Your Choice of Channel Determines Your Compliance

A mass email or push notification in an app already in place costs nothing extra to send during a campaign compared to a normal day. A boosted Facebook campaign, on the other hand, costs money and falls directly under the regime of prohibited electoral expenses from the moment the campaign starts. The choice of channel is not just a question of communication effectiveness. It is a question of legal compliance.

Your Executive's Checklist Before the End of August

Set a single official channel now for all election-related communications
Have your legal services validate any activity involving a disbursement between the campaign launch and October 5
Send a voter list verification reminder before mid-September
Reserve existing, free channels for neutral information: voter reminders, advance voting dates, polling station addresses
Document the date and content of every election-related message sent

How We Help

No more last-minute decisions on election communication compliance.

Fortisia is a channel your union already owns: distributing neutral information to your members creates no media buy, and therefore no new electoral expense to declare.

Your members have direct access to:

Your voter reminders and advance voting dates
Their polling station address
Your official communications, tracked and time-stamped
A push notification, without going through an overloaded inbox

Result: your executive communicates during the campaign without exposing your union to a fine.

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In Summary

Since January 1, 2026, Quebec unions are third parties under the Election Act. The campaign launch, projected for August 29, marks the real regime change: electoral expenses become essentially prohibited until the October 5 vote, and the particular intervenor status remains reserved for individuals, never for organizations. Fines for a legal person can reach $50,000.

What remains permitted at all times: distributing neutral information, such as voter reminders, through a channel your union already owns, with no media buy. That is exactly how Fortisia serves your communications during the campaign, without exposing your organization to a new electoral expense.

Frequently Asked Questions

When will the 2026 election campaign officially start?

Élections Québec projects an August 29, 2026 launch, with the vote on October 5. The election period typically lasts between 33 and 39 days.

Can a union run paid advertising during the election campaign?

No. Once the campaign launches, electoral expenses are essentially prohibited for all third parties, including unions. Only the official agents of parties and candidates can incur this type of expense.

What counts as an electoral expense under the Election Act?

Any intervention that has a cost and a partisan effect during the election period: advertising, a website, an app, an event. The effect is deemed partisan if it favours, disfavours, or takes a position on a party's or candidate's platform.

Does a union's mobile app fall under these rules?

Distributing neutral information through an existing app, with no media buy, does not create a new electoral expense. The risk arises if the content becomes partisan or if its production incurs an additional cost during the covered period.