Electronic Condo Voting in Quebec: AGM Rules Under Bill 25

Electronic voting at a co-owners’ meeting often raises the same question: is it legal in Quebec, particularly at the AGM of a divided co-ownership? The answer is yes, subject to certain conditions. The goal is to comply with the Civil Code of Quebec, the declaration of co-ownership (DCV) and Bill 25 on the protection of personal information, while ensuring transparency, fairness and traceability. (as of 2026-06-23)

With co-owners becoming increasingly mobile, electronic voting can increase participation, reduce logistical costs and speed up the compilation of results. However, the board of directors must establish clear rules, document voting evidence and adapt the by-laws of the immovable if necessary to avoid challenges.

What the law says in Quebec

• Civil Code of Quebec (C.c.Q.). The syndicate must hold meetings and make decisions according to the notice, quorum and majority rules that apply. Technological means are permitted if they allow for fair participation, identity verification and, where necessary, a secret ballot. Refer to the divided co-ownership provisions of the C.c.Q. and your declaration of co-ownership for the exact procedures.
• Act to establish a legal framework for information technology (LCJTI). It recognizes the functional equivalence between paper documents and signatures and their electronic equivalents, provided that integrity, accessibility and the ability to produce the document are ensured. In plain terms, an electronic ballot may be valid if its integrity and origin can be demonstrated.
• Bill 25 (modernization of the protection of personal information). Co-owner lists, email addresses, meeting recordings, attendance registers and ballots are personal information. The syndicate must implement governance measures (incident register, retention policies, consents and data minimization) and choose tools that adequately protect this information.

For more information:

• LégisQuébec – Civil Code of Quebec (includes the divided co-ownership rules)
• LégisQuébec – LCJTI (C-1.1)
• LégisQuébec – Act respecting the protection of personal information in the private sector (P-39.1), as amended by Bill 25
• RGCQ – Co-ownership resources and best practices

Conditions for valid electronic voting at the AGM

Before adopting electronic voting, make sure that the declaration of co-ownership and the by-laws of the immovable permit it, or that a meeting resolution authorizes it. Ideally, set out written procedures covering advance notice, the platform used, the handling of proxies, identity management and ballot secrecy.

Here are the key conditions to meet:

• Clear notice of meeting. State that the meeting will be virtual or hybrid, identify the broadcasting platform and explain the voting method. Attach a simple guide for co-owners.
• Identity verification. Use a robust mechanism (unique link, email/SMS code, verification of the unit and name). Record the method in the minutes.
• Equal access. Offer an accommodation solution for co-owners without the necessary equipment (telephone, on-site kiosk). Avoid any discriminatory barrier.
• Quorum and attendance. The platform must produce a log of connections and departures to calculate quorum in real time.
• Secret ballot where necessary. Some matters require a secret ballot: the solution must conceal individual choices while preserving proof of the aggregated results.
• Proxies. Manage the registration of proxyholders, the permitted number of proxies and the corresponding weighting of votes.
• Technical stability. Have a backup plan in case of failure (temporary suspension, resumption or adjournment). Inform participants in advance.
• Traceability. Require detailed audit logs: opening and closing of the vote, number of ballots, results and anomalies.
• Data protection (Bill 25). Encryption, access management, appropriate hosting, a retention policy and secure deletion.

Quorum, majorities and ballot secrecy

• Quorum: it is calculated based on co-owners present or represented. Electronic attendance is equivalent to attendance in the meeting room if the tool allows live interaction and attendance is recorded.
• Majorities: retain the rules set out in the declaration of co-ownership/C.c.Q. (simple, absolute or enhanced majority, depending on the matter). Technology does not change the thresholds; it only has to calculate them correctly.
• Secret ballot: if the meeting chooses a secret ballot, the platform must anonymize the ballot while allowing the scrutineer to validate the total number and eligibility of voters.

Proxies and hybrid participation

• Submitting proxies: require them to be sent in advance, or submitted through the platform, with verification of their authenticity. Record the mandates in the attendance list.
• Hybrid meetings: provide an on-site voting station for those participating in person, and synchronize the ballot so that everyone votes during the same time window.

Choosing a platform: criteria and compliance with Bill 25

When selecting an electronic voting tool suited to a co-ownership, assess the following criteria:

• Encryption in transit and at rest, role-based access management (administrator, scrutineer and co-owner), and multifactor authentication for the board of directors.
• Data hosting and location. Prefer hosting in Canada or, failing that, contractual clauses offering equivalent protection and audit rights.
• Data minimization. The tool should not require more than necessary (name, unit, email address and voting weight, if applicable).
• Downloadable audit logs (timestamps for opening and closing votes, number of voters, results, errors and denied access attempts).
• AGM features: quorum management, virtual show of hands, secret ballot, weighting of co-ownership shares, proxies and exports for the minutes.
• Accessibility: French-language interface, mobile compatibility and options for participants by telephone.
• Continuity: backups, disaster recovery and live support during the AGM.
• Contract and Bill 25 compliance: personal information protection agreement, security schedule, and clear retention and deletion periods.

The board of directors can mandate the condominium manager to lead the implementation, train the scrutineers and conduct a technical test. See our administrative management service for support in preparing AGMs and holding votes: https://www.multirent.ca/services/#gestion-administrative

Evidence and retention: what to keep and for how long

In the event of a challenge, the strength of your file rests on complete, reliable and traceable evidence. Create an “AGM file” containing:

• Notice of meeting, agenda and explanatory documents sent to co-owners.
• Attendance register (entries and exits), recorded with the opening and closing times.
• Parameters for each ballot (secret or not, weighting and allotted time).
• Audit logs and result reports signed by the chair and secretary of the meeting, or by the scrutineers.
• Records of technical issues (failures and adjournments), with the chair’s decision and communication to participants.
• Consents relating to personal information, and the retention/deletion policy approved by the board of directors.
• Minutes of the AGM, sent within the deadlines set out in the declaration of co-ownership and the C.c.Q., with the results attached.

Your declaration of co-ownership may set minimum retention periods for the syndicate’s records. If it does not, apply a policy based on legal obligations and best practices, and record it in a board of directors resolution. For general guidance and useful documentation on co-ownership governance, consult the RGCQ: https://rgcq.org/

Examples of voting methods and evidence to retain:

Frequently asked questions (FAQ)

Q1. Is it legal to hold an electronic vote at the AGM of a co-ownership syndicate?

Yes, provided that the notice, quorum and majority rules in the C.c.Q. and your declaration of co-ownership are followed, and that the technological means ensure proper identification of co-owners and the integrity of the process. The LCJTI recognizes the validity of electronic documents, and Bill 25 governs the protection of personal information.

Q2. Can a co-owner who refuses to use the technology prevent a virtual AGM?

No, not if reasonable accommodation measures are available (telephone line, on-site voting station or assistance). The board of directors must nevertheless ensure that everyone can exercise their voting rights without undue obstacles, and clearly communicate this in the notice of meeting.

Q3. What should you do if a failure occurs during an electronic ballot?

The chair may suspend the vote, request a technical review and then resume or adjourn the meeting, depending on the seriousness of the issue. Record the steps in the minutes, retain the incident logs and communicate the procedure to the co-owners.

For more practical advice and templates, browse our blog: https://www.multirent.ca/blogue/ and learn more about us: https://www.multirent.ca/qui-sommes-nous/

This article provides general information and does not constitute legal advice. For your situation, consult a lawyer or notary.

Do you manage a co-ownership in Quebec? Explore our plans or contact us to assess your needs.