On January 19, 2024, the Canadian Radio-Television and Telecommunications Commission (CRTC) sent a letter to all registered telecommunications service providers (TSPs), urging all TSPs who are required to provide access to emergency calling services in Canada to ensure that their customers have access to 911 services in the official language of their choice. Canada’s official languages are English and French, and both official languages have equal status under the Canadian Charter of Rights and Freedoms and the Official Languages Act. The letter specifically urges TSPs to “review their contracts with emergency third-party call centers without delay.” Additionally, we remind all companies doing business in Quebec that they have additional French language obligations under provincial law.
According to the letter, the CRTC is actively investigating recent incidents where Canadians have reported being unable to obtain emergency services in the official language of their choice. The CRTC recognizes that these types of situations can cause life-threatening delays or have other adverse public safety consequences. In light of these incidents, the CRTC reminds TSPs that their customers expect them to ensure access to 911 services.
To prevent these types of incidents in the future, the CRTC urges all TSPs who are required to provide 911 access to review and renegotiate their contracts with public safety answering points and other third-party call centers, as applicable, to ensure that a 911 caller can communicate with the 911 operator in English or French. Likewise, any public disclosures on the capabilities or limitations of provided 911 services —whether published on a TSP’s website or included in product starter kits — should be bilingual.
Although we have subsequently confirmed with CRTC staff that the provision of bilingual 911 services is not mandatory, we encourage TSPs to take the CRTC’s request seriously. Even if your company currently does business in Canada in English only, adding French language support for its 911 services could save lives. And the more TSPs get on board voluntarily, the less inclined the CRTC may be to mandate bilingual 911 access formally in the future.
We also remind TSPs and other companies doing business in Quebec that they have much broader French language obligations under Quebec’s Charter of the French Language (French Charter) to the extent they engage in commercial activities in the province. Most notably, they must serve and inform their Quebec customers in French, which encompasses nearly all aspects of the customer relationship, including marketing, billing, and technical support. Unlike the laws and regulations under the CRTC’s jurisdiction, the French Charter is enforced aggressively. Failure to comply with the French Charter can lead to lawsuits and steep fines.
Our experienced telecom attorneys stand by ready to help you navigate your company’s potential French language obligations arising from doing business in Canada. We can advise on what is required, the potential risks of non-compliance, and how to meet applicable language requirements.
If you would like to discuss how your company can provide bilingual 911 services or its potential French language obligations under the French Charter, please contact Michal J. Nowicki at (703) 714-1311 or mjn@commlawgroup.com.
