Bill 98 The APTS denounces an attempt to silence civil society
April 22, 2025

Longueuil – The APTS (Alliance du personnel professionnel et technique de la santé et des services sociaux) is deeply worried about the impact of Bill 98, tabled by Jean-François Roberge, the minister responsible for democratic institutions. Introduced under the guise of fighting election disinformation, the bill sets up restrictions that could seriously threaten the freedom of expression of unions and citizens’ groups in the period leading up to an election.
“This bill threatens to stifle public debate by imposing ludicrous rules on voices that challenge established powers,” said APTS president Robert Comeau. “We’re talking about measures that will force groups to produce reports and statements whenever they spend more than $1,000, starting on January 1 of an election year. Meanwhile, political parties will not have to obey these rules until July. This is a two-track democracy we’re looking at.”
The APTS identified three particularly troubling aspects of the bill:
• “Third parties” would face a longer pre-election period than political parties, creating an unjustified imbalance.
• A restrictive and complex registration requirement would be triggered even by minimal spending on ads focusing on matters of public interest.
• There is no clear legal definition of what it means to “promote” or “oppose” a political party, which opens the door to arbitrary interpretation.
The APTS argues that enforcing the provisions of the bill would constitute a significant threat to freedom of expression in a pre-election period, especially in a context where Québec’s Chief Electoral Officer (DGEQ) has been using an increasingly narrow interpretation of what counts as “partisan” advertising. Already, during the 2022 election campaign, a number of civil society organizations were served legal warnings by DGEQ for speaking out on social issues even when they did not include any partisan content.
The APTS urges political parties to demand that these provisions be withdrawn from the bill, that the bill itself be subject to careful examination, and that it be amended to protect freedom of expression during the run-up to elections.
“At a time when trust in democratic institutions is under significant pressure, it is vitally important to strengthen – rather than restrict – citizens’ voices in our public debates,” said the APTS president. “Making even small changes to Québec’s Election Act should be unthinkable unless there is a genuine process to consult civil society.”
The APTS
The APTS (Alliance du personnel professionnel et technique de la santé et des services sociaux) represents more than 65,000 members who play a key role in ensuring that health and social services institutions run smoothly. Our members provide a wide range of services for all Quebecers, including diagnostic, rehabilitation, nutrition, psychosocial intervention, clinical support, and prevention services.