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Canada

Software development for Canadian businesses

Custom software, AI and SaaS for companies building under Canadian obligations. Here the rules reach the surface your users actually touch — the language it renders in, whether it can be operated without a mouse, whether a person can contest an automated decision. Those are product decisions, and they are cheapest in week one.

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The starting point

What Canadian law puts on the screen

Most compliance conversations are about data at rest. Canada's are unusual in how much of the obligation reaches the interface itself. These four are the ones that change what gets built.

The product may have to exist in French

The Charter of the French Language, amended by Bill 96 and assented to on 1 June 2022, treats commercial websites and software as material that Quebec consumers and business clients are entitled to receive in French. The requirement is parity rather than presence: the French version has to match the other language in content, presentation and functionality, so a translated marketing page attached to an English-only application does not satisfy it. Since 1 June 2025 the rules also govern prominence, and no language may be given greater visual weight than French.

Accessibility is a filing obligation, not a best practice

Under Ontario Regulation 191/11 public-facing web content had to meet WCAG 2.0 Level AA by 1 January 2021 for public sector organisations and for private organisations with fifty or more employees. Federally regulated organisations work to WCAG 2.1 Level AA under the Accessible Canada Act. What makes this different from a design preference is the paperwork attached: organisations with twenty or more employees file an accessibility compliance report, and the next one is due 31 December 2026. A province-wide move to WCAG 2.2 is expected in 2027.

An automated decision needs a route to a human

Section 12.1 of Quebec's Law 25 has applied since 22 September 2023. Where a decision is based exclusively on automated processing of personal information, the person has to be told at the time of the decision, given the principal factors and parameters behind it, and offered the opportunity to submit observations to someone who is in a position to review it. That last part is a screen, a queue and a role — not a paragraph in a privacy policy. It is also self-limiting in a useful way: where the human review is genuine, the decision stops being exclusively automated.

Messaging carries its own consent regime

Canada's Anti-Spam Legislation governs commercial electronic messages on a consent basis rather than an opt-out one, and its mechanics are specific enough to be build requirements. An unsubscribe request has to be honoured within ten business days, and the unsubscribe mechanism has to stay valid for at least sixty days after the message was sent. Systems that record a marketing preference but not the evidence behind it — what was consented to, when, and by which route — cannot answer the only question that matters if the consent is ever challenged.

Quebec

Where French stops being a translation task

Quebec is the part of this market that most changes an engineering plan, and the part suppliers most often quote as though it were a content exercise. It is not.

Bilingual is an architecture decision, not a content task

Teams usually discover the cost of French late, because it looks like a content problem and behaves like a structural one. Strings living inside components rather than in a resource layer, layouts that break when text expands, dates and currency formatted for one locale, emails and PDFs generated from templates nobody counted, and a QA plan that now has to cover every path twice. None of that is difficult when it is decided in week one. All of it is expensive once a product is live, which is why we raise it during scoping rather than treating it as a later phase.

Where our part ends, and where it does not

We build the mechanism: the internationalisation layer, the locale routing, the parity checks that stop one language quietly falling behind the other, and the tests that catch it when it does. We do not write French copy and we do not provide translation — that is a separate specialism, it needs to be Quebec French rather than French generally, and you should source it from someone who does it properly. Saying so costs us nothing and saves a conversation later, because a supplier who implies otherwise is telling you something about how they scope.

Portability has a format requirement attached

Since 22 September 2024 Law 25 has given individuals the right to receive computerised personal information they provided in a structured and commonly used technological format, with the request answered within thirty days. Guidance published by the Quebec government points to formats such as CSV, XML and JSON, and specifically treats images and PDFs as not meeting the requirement. Exporting a rendered document is therefore the intuitive answer and the wrong one. Law 25 also expects a privacy impact assessment when a project acquires, develops or overhauls an information system involving personal information.

Recent legislation

What changed this year

Two significant statutes received assent in 2026, and most published guidance predates both. Just as useful as knowing what they require is knowing what is not yet in force — which, in two cases here, is the substance of it.

Screen scraping is on its way out

Bill C-15, the Budget 2025 Implementation Act, No. 1, received royal assent on 26 March 2026 and replaced the earlier Consumer-Driven Banking Act with a fuller framework. Two parts of it reach software directly. Financial data sharing moves onto accredited interfaces, and screen scraping — collecting a customer's data by logging in with their credentials — becomes an offence rather than a tolerated workaround. Any product still acquiring bank data that way has a migration ahead of it, and the sequencing of that migration is a product decision as much as a technical one.

The regulator changed, which changes who you answer to

Supervision of the consumer-driven banking framework now sits with the Bank of Canada rather than the Financial Consumer Agency of Canada, alongside its existing retail payments mandate. Accreditation, the public registry and the assessment of applicants run through it. The technical standards, the accreditation criteria and the scope of participating entities and data types are still to come through regulation, so the honest position in mid-2026 is that the framework exists in statute and the detail a build would need does not yet exist. Read access has been described as the first phase, with write access targeted later.

A federal portability right exists, but is not in force

The same bill amended PIPEDA to add the first federal data-mobility right, requiring an organisation to disclose an individual's personal information to another designated organisation on request. It is worth knowing precisely what that does and does not mean today. The right comes into force on a day fixed by order of the Governor in Council, and it operates only once regulations establish a data-mobility framework for the sector concerned. Nothing is owed under it yet. Building toward it now is reasonable planning; describing it as a current obligation is not.

The cyber statute passed with nobody designated

Bill C-8 received royal assent on 15 June 2026, amending the Telecommunications Act and enacting the Critical Cyber Systems Protection Act for federally regulated sectors including telecommunications, banking, nuclear energy, clearing and settlement, federally regulated transportation, and interprovincial pipelines and power lines. The telecommunications amendments took effect on assent. The Act's own obligations begin on dates fixed by order in council, and its schedule of designated operator classes is empty, so no organisation carries them yet. It is a thing to watch rather than a thing to comply with today.

Oversight

How a supplier ends up in your risk register

In Canada a software supplier can sit inside its customer's supervision without ever being regulated itself. Knowing which of these applies before the contract is signed avoids a difficult month afterwards.

Your bank client has to account for you

OSFI's Guideline B-10 on third-party risk management took effect on 1 May 2024 and applies to federally regulated financial institutions. Its practical consequence for a software supplier is indirect but concrete: the institution is accountable for risk arising from its third-party arrangements, so a supplier becomes an entry in a register with controls attached to it. The security questionnaire that arrives after the contract is signed is usually this, and it is far easier to answer from a system that was built to produce evidence than from one where the answers have to be reconstructed.

Technology risk has a named guideline behind it

Guideline B-13 on technology and cyber risk management took effect on 1 January 2024 and sets expectations for how federally regulated institutions govern technology, manage change, and run operations. A supplier does not comply with B-13 — the institution does. But the expectations flow down through the arrangement, which is why questions about environment separation, change control, access review and incident handling arrive on projects that seemed, at the proposal stage, to be a straightforward build.

Handling payments is now a registration, not a feature

Under the Retail Payment Activities Act the transition window closed on 7 September 2025. Since 8 September 2025, an entity that intends to perform retail payment activities must be registered with the Bank of Canada before performing them. This catches teams out because the trigger is the activity rather than the self-description: a platform that moves funds on behalf of its users may be a payment service provider whether or not it thinks of itself as one. It is a question worth settling during scoping, since the answer can change the architecture and the launch sequence.

Safeguarding and reporting are build requirements

Registered providers have to document a framework for managing operational risk and responding to incidents, and where they hold end-user funds those funds have to be safeguarded — held in a segregated trust account, or covered by insurance or a guarantee from an unaffiliated financial institution, in an amount that keeps pace with what is actually held. There is an annual report attached; the first fell due on 31 March 2026. Systems that commingle balances, or that cannot show the coverage position on a given date, make that reporting considerably harder than it needs to be.

Research credits

The one rule that argues against hiring us

Canada funds research and development through a tax credit, and where the work physically happens decides whether it counts. This is the part of the Canadian market that genuinely favours a local supplier, so here it is stated plainly rather than left for you to find.

The rule that decides this

The Scientific Research and Experimental Development programme is the largest source of federal support for research and development in Canada, and software work can qualify. The constraint that matters when choosing a supplier is where the work happens. Eighty per cent of amounts paid to arm's-length contractors are eligible only where the SR&ED work is performed in Canada. Bill C-15 improved the programme in other ways, raising the expenditure limit for the enhanced refundable credit and restoring eligibility for certain capital expenditures, but it did not change that.

What this means for working with us

Development we perform outside Canada is not eligible contractor expenditure for your claim. If the credit is a material part of how the project is funded, that is a genuine reason to prefer a supplier performing the work in Canada, and we would rather you weigh it before the engagement than discover it during a filing. Suppliers do advertise SR&ED support without mentioning the residency rule. Ask any of them where the work will physically be performed, and ask before the proposal rather than after it.

Where it still does not decide anything

The credit only reaches work that qualifies as SR&ED in the first place — systematic investigation directed at resolving a technological uncertainty. A great deal of valuable software is not that. Building a well-understood integration, a reporting layer, a customer portal or a second version of something that already works is ordinary engineering, and no supplier's location changes its treatment. Establishing early which parts of a roadmap could plausibly qualify is worth more than assuming the whole project does, because the assumption is usually generous.

Two languages, one product

Quebec obligations handled in the build, not bolted on after launch.

Who this reaches

Where these obligations concentrate

Grouped by the obligation that reaches them rather than by industry, because in Canada that is what actually decides the engineering. Described by the shape of the problem, never by listing client names we are not free to publish.

Products with Quebec users

Defined by jurisdiction rather than by industry, because the obligations follow the user. A product with a meaningful Quebec user base inherits language parity, the automated-decision route to a human, and a portability right with a format requirement — regardless of whether it is a marketplace, a scheduling tool or an internal platform. The engineering consequence is that the locale layer, the consent record and the export path stop being separate features and start being one design problem.

Payments and money movement

Not fintech as a category, but the narrower question of whether a system performs a retail payment activity and therefore needs registration before launch. The recurring problem is that funds flow is discovered late: a platform adds balances, or holds money between a transaction and a payout, and a feature turns into a regulatory trigger. Safeguarding, segregation and being able to evidence the coverage position on a given date are all much cheaper as design decisions than as retrofits.

Suppliers to regulated institutions

Software companies whose customers are banks, insurers or their service providers, where the buyer's own supervision reaches through the contract. These builds are judged on what can be evidenced rather than on what works — environment separation, change control, access review, incident handling — and the questions usually arrive after the deal, from a risk team who were not in the sales conversation. Building the evidence trail from the first sprint is the difference between answering a questionnaire and reconstructing a year of decisions.

Public-facing services under accessibility duties

Organisations whose web content is covered by AODA or the Accessible Canada Act, which is a far wider group than the public sector alone. The engineering reality is that conformance is decided by component behaviour rather than by a remediation pass — focus management, keyboard paths, name and role on custom controls, and error handling that a screen reader can actually follow. Retrofitting those into a finished interface routinely costs more than building them, and the compliance report has a date on it either way.

Fit

When to hire in Canada, and when not to

Every reason below turns on something that is only true in Canada. Where a local supplier is the better answer, we would rather say so than compete for work we are not the right choice for.

When a Canadian supplier is the better answer

  • Projects where the research and development credit is part of the funding model, because contractor work has to be performed in Canada to be claimable.

  • Products where French has to be owned end to end rather than implemented, including the copy itself and the judgement about what reads correctly in Quebec.

  • Procurement that requires a Canadian contracting entity, which several provincial and broader public-sector processes do outright.

  • Arrangements where a regulated buyer needs supplier controls evidenced within its own jurisdiction as part of its third-party oversight.

When a distributed team is the better answer

  • Engineering depth that is needed intensely and then not at all, which is expensive to carry on a permanent local payroll.

  • Delivery against a scope that is already written down, where the limiting factor is capacity rather than availability in a calendar.

  • Work that is ordinary engineering rather than experimental development, so the research credit was never going to apply to it.

  • Budgets that need to reach the build rather than the layer of account management sitting above it.

How these engagements actually go wrong here

  • French treated as a translation pass before launch, when it was an architecture decision in week one.

  • Accessibility booked as an audit near the end, which finds problems in components rather than in content.

  • A research credit assumed rather than checked, and the residency question asked after the invoices exist.

  • Consent captured as a preference flag with no record of what was agreed to, when, or through which route.

Budgeting

What moves a Canadian estimate

Two things distinguish a Canadian number from the same feature list quoted anywhere else, and a third changes what the project ultimately costs you without changing the quote at all.

A second language is a second surface

The most common estimating mistake on Canadian projects is treating French as a percentage uplift on content. It is closer to a second surface of the same product: layouts that hold when text expands, resource files instead of inline strings, notifications and generated documents in both languages, and a test plan that covers each path twice. Decided at the start it is a modest structural choice. Decided after launch it is a migration, and the number reflects that.

Conformance is cheaper as a constraint than as a fix

Accessibility work priced as a remediation project is consistently more expensive than the same conformance built in, because the findings land in shared components and in interaction patterns rather than in copy. That is also why an audit late in a build often produces a bill larger than the audit. We treat the target level as a constraint on the component library from the beginning, which makes it a design decision rather than a line item.

The credit changes the net number, not the quote

Where a research credit is in play it can alter the effective cost of a project materially, and it belongs in the comparison you are making between suppliers. It does not change our estimate, and we do not build it into one. What we will do is be explicit that work performed outside Canada is not eligible contractor expenditure, so you can put a real number against that difference rather than an assumed one.

Ranges you can check before booking anything

We publish detailed cost breakdowns for custom software, SaaS platforms and AI agents rather than requiring a call to establish whether a budget is plausible. Read the guide that matches the project, compare it against quotes you already hold, and arrive knowing whether the numbers are in range. A scoping conversation is a poor way for either side to discover a mismatch that a published range settles in a minute.

See what drives an estimate

Canada FAQ

Questions from Canadian buyers.

What Canadian enquirers ask before the first call, including two questions whose honest answer does not help us win the work. If yours is not here, send it over.

If you are selling to consumers or business clients in Quebec, assume yes. The Charter of the French Language treats commercial websites and software as material Quebec customers are entitled to receive in French, and the standard is parity rather than presence — the French version has to match in content, presentation and functionality. Since 1 June 2025 the prominence rules also mean no other language may be given greater visual weight. The practical question is not whether to translate but whether the product is built so that it can be.

Start in Canada

Building for users in Canada or Quebec?

Book a scoping call, or send us the scope and we'll come back with a written understanding of what you are building and which obligations reach it.