Starting a Personnel Placement Agency in Quebec: CNESST Licence, Bond and Obligations (2026)
To start a personnel placement agency in Quebec, you first need a registered business (NEQ), then a CNESST licence: $1,087 per year in 2026, a $15,000 bond and a Revenu Québec attestation. And forget the “licence valid for 2 years” claim that still circulates: since the 2023 reform, the licence is issued with no fixed term. This guide reflects the current regime.
If you are placing your own expertise rather than personnel, see our guide to incorporating as a consultant in Quebec. Economic activity codes (CAE) to declare to the Registrar for an agency: 7711 (placement offices and agencies) or 7712 (personnel leasing services) — see our CAE code lookup tool.
Who needs a CNESST licence? Placement, TFW recruitment or headhunting
The personnel placement agency licence applies to any business with at least one activity that consists of offering personnel leasing: supplying its own employees to a client business that directs them. A single incidental activity is enough. Recruiting temporary foreign workers (TFW) requires a separate licence, and a pure headhunter needs no placement licence at all.
The key criterion: in personnel leasing, the employee remains the agency's employee but works under the client's direction — which distinguishes it from a service contract (performing a job for a price) and from permanent recruitment.
| Personnel placement agency | TFW recruitment agency | Headhunter | |
|---|---|---|---|
| Activity covered | Personnel leasing: your employees work under the client's direction | TFW recruitment and helping the client with the process | The candidate becomes directly the client's employee |
| CNESST licence | Mandatory | Mandatory (separate licence) | Not required — except the TFW licence if recruiting foreign workers |
| Bond | $15,000 | None | None |
| 2026 fee | $1,087 per year | $1,087 per year | — |
Two warnings from the CNESST: incidental activity counts — the consulting firm that “lent” a few workers still has to hold the licence — and two activities = two licences, i.e. 2 × $1,087 per year.
A licence with no fixed term, annual fees: forget the “valid for 2 years”
Since the 2023 reform, the agency licence is issued with no fixed term: it no longer expires, and there is no longer a two-year renewal. In exchange, annual fees — $1,087 in 2026, indexed every January 1 — are required before each anniversary date, on pain of losing the licence.
The “licence valid for 2 years” that many websites still repeat describes the pre-reform regime. Maintaining the licence now rests on three ongoing conditions: annual fees paid before the anniversary date, a Revenu Québec attestation valid at all times, and the issuance conditions met. The first fees, non-refundable, must be paid for the application to be processed.
Another structuring rule: the licence is non-transferable and the NEQ is a mandatory field on the application. Your business must therefore exist in the Quebec Enterprise Register before you file, and a later change in legal structure (new NEQ) requires redoing everything. Structure before: our guide When should you incorporate in Quebec? helps you decide.
The $15,000 bond: surety policy or cash deposit?
Only personnel placement agencies provide a $15,000 bond — TFW recruitment agencies are exempt from it. Two forms are accepted: a surety bond issued by an authorized insurer, which avoids tying up the amount, or a deposit by cheque or money order, whose funds remain frozen for three years after the licence ends.
The bond policy — issued by an insurer listed on the AMF's register; it is not a bank letter of guarantee — costs you a premium instead of $15,000 in cash. The deposit (with an undertaking form), on the other hand, is held for three years after the licence ends, whether it was used or not. At start-up, the bond policy is almost always the better choice.
Application requirements — and grounds for refusal
The application is filed through MonEspace CNESST for employers and rests on four pieces: a designated respondent officer appointed by resolution, a valid Revenu Québec attestation, a declaration of background and the bond. The CNESST also examines the history of the business and of each of its officers — certain backgrounds block issuance.
In detail:
- The respondent: an individual aged 18 or older, an officer of the business, mandated for communications with the CNESST — authorized by resolution (CNESST template available), to be recorded in your minute book;
- The Revenu Québec attestation: free, but valid only for three months after the end of the month of issuance — subscribe to automatic renewal, since the CNESST is informed of your status directly;
- The respondent's declaration of background and bankruptcies, and the identity of all officers — including any shareholder holding 10% or more of the voting rights.
Among the grounds for refusal: bankruptcy (particularly within the last two years), an irrevocable conviction for discrimination, harassment or reprisals within two years, an offence related to the activities within five years, amounts owed to a public body, acting as a nominee, or a false declaration. After a refusal or revocation: a two-year wait, unless new facts arise.
How much does it cost to start an agency in 2026?
The bulk of the start-up budget is not incorporation: it's the $15,000 bond — avoidable in cash terms with a bond policy — and the $1,087-per-year licence. Incorporating the company costs $397 in government fees doing it yourself, or $497 all-in with Incorp-Québec.
| Item (2026) | Amount |
|---|---|
| Incorporating the company (Registrar) | $397 — included in our packages |
| Incorp-Québec — Essential (numbered company, articles, initial declaration, government fees included) | $497 all-in |
| Incorp-Québec — Complete (+ official name, GST/QST and source deductions registrations, express service) | $697 all-in |
| CNESST licence (each licence, indexed every January 1) | $1,087 per year |
| Placement + TFW recruitment | 2 × $1,087 per year |
| Bond (placement only) | $15,000 (surety bond or deposit) |
| Revenu Québec attestation | Free — valid 3 months after the end of the month of issuance |
| Annual rights to the Registrar (recurring) | $106 per year |
Details in our guide to Quebec incorporation costs; an overview of the process and packages on our page incorporating in Quebec online.
Your operating obligations, in a table
Once you hold the licence, the law tightly regulates operations: joint and several liability with your clients, wage parity with their employees, a ban on charging candidates anything, retention clauses capped at six months, and the licence number displayed everywhere. Here is the essential.
| Obligation | In practice |
|---|---|
| Joint and several liability (Act respecting labour standards, s. 95) | Agency and client jointly and severally liable for the pecuniary obligations set out in the Act |
| Wage parity (Act respecting labour standards, s. 41.2) | No rate lower than that of the client's employees performing the same tasks at the same establishment |
| No fees to candidates | Neither for the assignment, nor for required training, nor for hiring assistance |
| Capped retention clause | Cannot prevent the client from hiring your employee beyond 6 months of assignment |
| Visible licence number | On invoices, contracts, website and advertising; licence displayed at each establishment |
| Records kept for 6 years | Client contracts, invoices, hours worked per day and per week for each assigned employee |
| Public register | Your clients can verify your licence; suspensions and revocations are public there |
Added to this, for each assignment: giving the employee a document describing their conditions (with the CNESST leaflet) and reminding the client of its OHS obligations.
Operating without a licence: 2026 fines — and why compliance sells
Operating an agency without a licence exposes you to a fine of $1,000 to $25,000 for an individual and $2,000 to $50,000 for a corporation — doubled on a first repeat offence, then tripled. And the client business that uses an unlicensed agency is exposed to the same fines, which makes your compliance a measurable selling point.
The officer is also presumed to have personally committed the corporation's offence, unless due diligence is proven — and the public register of licence holders lets any client check your status in a few seconds.
That's the realistic angle for 2026: sector revenues declined in 2024 — don't count on a wave of growth, but on the regulatory barrier that keeps out the unprepared, given clients who are required to check the register. A compliant agency starts with a head start.
You are the employer of your temporary workers
In the CNESST's eyes, your temporary workers are your employees: registration as an employer from the first hire, OHS insurance premium based on your classification unit, pay equity including assigned staff. Health and safety obligations, on the other hand, are shared with the client — and cannot be transferred by contract.
2026 premium rates vary enormously depending on the personnel leased (general rates, per $100 of payroll): $0.47 for office workers, $3.76 for warehouse or plant personnel, $6.46 for truck drivers and delivery drivers. Your niche determines your employer costs — factor them into your pricing, along with your source deductions and GST/QST registrations.
Recruiting temporary foreign workers: the second licence, in brief
Recruiting TFWs for your clients requires the recruitment agency licence — with no bond — and brings your agency into the immigration process: an LMIA (labour market impact assessment) federally, temporary selection with the MIFI (Quebec's Ministry of Immigration, Francization and Integration), then a CAQ and a work permit. Any employee who advises on immigration matters must hold the official consultant recognition.
Both applications (LMIA and temporary selection) are submitted simultaneously — the process is described on Québec.ca. On the obligations side: notify the CNESST without delay of the TFW's arrival, the length of the contract and any early departure; it is prohibited to require custody of personal documents or to charge recruitment fees not authorized by a government program.
The steps, in the right order
The order of the steps is dictated by the very structure of the application: no NEQ, no licence application; no tax registrations, no Revenu Québec attestation; no bond and resolution, no complete file. Here is the sequence that avoids back-and-forth.
- Incorporate the company and obtain the NEQ. Since the licence is not transferable, choose your final structure now — see the incorporation steps, then open the business bank account;
- Complete the employer registrations: CNESST (from the first hire) and Revenu Québec files;
- Obtain the Revenu Québec attestation — and activate the automatic renewal subscription;
- Set up the $15,000 bond (placement): a policy with an authorized insurer, or a deposit with an undertaking form;
- Adopt the resolution designating the respondent officer and complete the declaration of background;
- File the application through MonEspace CNESST and pay the initial $1,087 fee — the application is not processed before payment;
- Operate in compliance: licence displayed, number on invoices and the site, assignment documents, records kept 6 years, wage parity, annual fees paid before each anniversary date.
Step 1, handled for $497 — government fees included
Your company incorporated with the Registrar, with articles, initial declaration and NEQ — the mandatory prerequisite for any agency licence application. A form that takes about 20 minutes.
The pitfalls that cost you
The costly mistakes involve the bond deposited in cash, an expired tax attestation, the non-transferable licence, or an illegal retention clause. Six documented pitfalls.
- The $15,000 deposit stays frozen for three years after the licence ends, no exceptions — the bond policy avoids tying up the amount;
- The Revenu Québec attestation expires quickly, and its expiry is grounds for suspension, of which the CNESST is informed automatically — automatic renewal is your safety net;
- The licence does not follow your structure: a change in legal structure = new NEQ = new application. And closing your employer file does not cancel the licence — annual fees keep accruing as long as the cancellation form is not received before the anniversary date;
- Two activities, two licences: placement and TFW recruitment stack, at 2 × $1,087 per year;
- “Buy-out” clauses are capped at 6 months of assignment — and they all automatically lapse if your licence is suspended, revoked or cancelled;
- Your client is co-liable: fines if it uses an unlicensed agency, joint and several liability for pecuniary obligations. It will check the register — make that a selling point.
FAQ — Starting a personnel placement agency in Quebec
Who needs to hold a personnel placement agency licence in Quebec?
Any business with at least one activity that consists of leasing out personnel — supplying its own employees to a client business that directs them — even if that activity is incidental: a consulting firm that “lends” a few workers to a client is covered.
Does a headhunter need a CNESST licence?
Not for placement: if the candidate becomes directly the client's employee, there is no personnel leasing. But if the headhunter recruits temporary foreign workers, the TFW licence is mandatory — it is a recruitment licence, not a leasing one.
How much does the agency licence cost in 2026?
$1,087 per licence, payable on issuance and then every year on the anniversary date, indexed every January 1 and non-refundable. Placement and TFW recruitment together: two licences, i.e. 2 × $1,087 per year.
Is the agency licence valid for two years?
No — that information is outdated. Since the 2023 reform, the licence is issued with no fixed term: it does not expire, and there is no longer a two-year renewal. It stays valid as long as the annual fees are paid and the conditions for maintaining it are met.
In what form must the $15,000 bond be provided?
Two options: a surety bond issued in favour of the CNESST by an authorized insurer — which avoids tying up $15,000 — or a cheque or money order accompanied by an undertaking form. TFW recruitment agencies, for their part, do not have to post any bond.
Do you have to be incorporated before applying for the licence?
The NEQ is a mandatory field on the application: you must incorporate your corporation or register before applying. Since the licence is not transferable, a change in legal structure (new NEQ) requires redoing the entire application — settle on your final structure from the outset.
What does an agency risk if it operates without a licence?
A fine of $1,000 to $25,000 (individual) or $2,000 to $50,000 (corporation), doubled on a first repeat offence and then tripled. The officer is presumed to have personally committed the corporation's offence, unless due diligence is proven.
Does my client risk anything if my licence is not valid?
Yes: a client who retains the services of an unlicensed agency is exposed to the same fine ranges. Serious clients therefore check the CNESST's public register before signing — a licence in good standing is a selling point.
Do I have to pay my temporary workers the same rate as the client's employees?
Yes, for the wage rate: it is prohibited to pay an agency employee a lower rate than the client's employees who perform the same tasks at the same establishment, solely because of their employment status.
Can the client hire my temporary worker?
Yes. Any clause restricting their hiring is capped at 6 months after the start of the assignment, and no fees may be charged to the employee. These clauses also lapse if the licence is suspended, revoked or cancelled.
Incorp-Québec is an incorporation document preparation service: we prepare and file your incorporation documents. We do not guarantee that a licence will be issued, and the steps with the CNESST (MonEspace, bond, attestation) are carried out by you. For advice tailored to your situation, consult a lawyer.