Loi 25 co-ownership register: privacy and access

Bill 25 modernizes the protection of personal information in Quebec. It directly affects the management of a divided co-ownership’s register. Your board of directors (board) must now balance transparency towards co-owners with increased data confidentiality. This article, up to date as of 2026-05-06, explains the practical impact on your register, access, retention and new obligations.

Why the co-ownership register contains personal information

The syndicate’s register brings together documents that are essential to the life of your condo. Under the Civil Code of Quebec (see the provisions relating to divided co-ownership), it notably includes the minutes of annual general meetings and special meetings, the declaration of co-ownership and its amendments, the by-laws of the immovable, financial statements, contracts, the maintenance logbook / contingency fund study, as well as the list of co-owners’ names and addresses.

These items contain personal information, such as contact information, signatures, information about unpaid special assessments or common expenses, and insurance details. Some financial documents may reveal sensitive situations. Unfiltered publication practices (e.g. distributing minutes detailing medical problems or disputes involving named individuals) expose the syndicate to risks since the gradual implementation of Bill 25 began (2022 to 2024 timeline, up to date as of 2026-05-06).

Access to the register remains a right of co-owners, but it is not unlimited. Bill 25 does not abolish this right; it requires better governance of what is collected, retained, communicated and redacted when required.

What Bill 25 changes for your syndicate

Bill 25 amends the Act respecting the protection of personal information in the private sector. It applies to syndicates of co-owners because they are private-sector organizations. Here are the key changes for the board:

• Person in charge of the protection of personal information: by default, the highest authority (the board) acts as the person in charge; a resolution may delegate this role to a specific person (e.g. the president or an external condominium manager), while the board remains accountable.
• Confidentiality incidents: there is an obligation to record every incident, assess the risk of serious harm and notify the individuals concerned and the competent authority when required.
• Governance and policies: establish internal policies on the collection, retention, destruction, access and response to requests. Publish a clear summary of privacy practices.
• Privacy impact assessments (PIA): for any project involving personal information (e.g. a digital portal or cloud hosting outside Quebec), carry out a PIA and document mitigation measures.
• Privacy by default and minimization: collect only the information that is necessary, limit access to people who genuinely need it and protect the data with appropriate controls.

Useful references: the Act respecting the protection of personal information in the private sector (P-39.1) and the Civil Code of Quebec for the rules governing access to the register. Consult LégisQuébec for up-to-date legislation.

Access to the register: who may consult it and what must be redacted?

The principle of access to the register by co-owners remains. However, the board must adjust how access is provided in light of Bill 25:

• People who usually have a right of access: co-owners, directors, the auditor, an appointed condominium manager and, in some cases, hypothecary lenders through a justified request. Access by the general public is not provided for.
• Access procedures: consultation by appointment, under controlled conditions; copies provided upon request, for reasonable fees. The by-laws of the immovable may specify the procedures and fees.
• Redaction: remove or conceal information that is not necessary for the purpose of the consultation. Common examples include bank account numbers, personal email addresses and telephone numbers, handwritten signatures, identity documents, and medical or disciplinary information.
• Minutes and annual general meetings: minutes must report decisions, quorum, votes and mandates without going into unnecessary details about individuals. Mentioning that a co-owner is in default of common expenses may be justified; publishing their email address is not.
• Mailing lists: using email addresses to communicate among co-owners requires consent. Without consent, favour a notice sent through the condominium manager or an official notice posted in accordance with the co-ownership rules.

In practice, prepare consultation-ready versions of the main documents (minutes, financial statements and contracts), with consistent redactions. This speeds up responses and limits risks.

Governance, retention and service providers: applying Bill 25 day to day

Good policies make compliance simpler and more consistent.

• Register access policy: describe the documents available, processing times, consultation hours, copying fees and redaction rules. Align everything with the declaration of co-ownership and the by-laws of the immovable.
• Retention and destruction: set periods by document type. Minutes and the declaration of co-ownership are retained permanently. Financial supporting documents are generally retained for several years; refer to Revenu Quebec’s tax requirements. Securely destroy them at the end of the period (shredding or certified erasure).
• Security: logical access controls (strong passwords and two-factor authentication for the portal), encrypted backups and physical filing under lock and key for paper files.
• Service providers: govern your mandates (condominium manager, accountant, insurer and IT provider) through confidentiality agreements and clauses specifying the purpose, duration, type of data and security measures. Assess the risk if hosting takes place outside Quebec and document the PIA.
• Training: periodically raise directors’ and the condominium manager’s awareness of best practices, especially during transitions after an annual general meeting.

Need help structuring your policies and processes? See our administrative and financial management services for mechanisms adapted to your syndicate.

What to do in the event of a confidentiality incident and pitfalls to avoid

A “confidentiality incident” includes unauthorized access, loss, use or communication of personal information without permission. Here is a simple protocol:

1. Contain: disable the compromised access, recover documents provided by mistake and limit further spread.
2. Assess: determine the sensitivity of the data, the number of people affected and the likelihood of serious harm (e.g. fraud or discrimination).
3. Notify: when the risk is serious, promptly notify the individuals concerned and the competent authority. Record the incident in the internal register.
4. Correct: implement measures to prevent a recurrence (add redactions, review minutes templates, require a second check before sending and encrypt attachments).

Pitfalls to avoid:

• Publishing overly narrative minutes that name co-owners and detail exchanges verbatim. Use a factual and concise style instead.
• Distributing the email list to everyone. Use blind-copy emails or platforms that conceal recipients.
• Retaining unnecessary information indefinitely (e.g. unsuccessful bids from 10 years ago). Apply a purge policy.
• Sharing “raw” documents with a potential buyer. Instead, direct them to a syndicate certificate and relevant, properly redacted excerpts.

FAQ — Bill 25 and the co-ownership register

Can the board refuse to show a register document by invoking Bill 25?

No, not outright. The right of access provided for in the Civil Code remains. However, Bill 25 requires the board to control the communication of personal information and redact personal information that is not necessary. The board must therefore arrange a controlled consultation or provide an expurgated copy.

Can notices of an annual general meeting be sent only by email?

Yes, if the declaration of co-ownership or the by-laws of the immovable allows it and if the co-owners have consented to receiving notices by email. Without consent, provide a compliant alternative method (mail, delivery or another prescribed method) to meet notification requirements.

What information from the “list of co-owners” may be shared?

The name and official address associated with the lot, as needed. Avoid distributing telephone numbers, email addresses and secondary contact information without consent. Limit use to the purpose of managing the co-ownership.

This article provides general information and does not constitute legal advice. Consult a lawyer or notary for your situation.

This article provides general information and does not replace advice from a tax specialist or accountant. Refer to Revenu Quebec and the CRA for the exact requirements.

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

Official resources and references

• LégisQuébec — Act respecting the protection of personal information in the private sector (P-39.1): https://www.legisquebec.gouv.qc.ca/fr/document/lc/P-39.1
• LégisQuéQuébec — Civil Code of Quebec (C.C.Q.), divided co-ownership: https://www.legisquebec.gouv.qc.ca/fr/document/lc/CCQ-1991
• Revenu Quebec — Document retention periods: https://www.revenuquebec.ca/fr/entreprises/obligations-fiscales/tenue-de-livres-et-de-registres/duree-de-conservation-des-documents/
• RGCQ — Best practices in co-ownership: https://rgcq.org/

Take things further with multiRent

• Our services — administrative management: https://www.multirent.ca/services/#gestion-administrative
• Our services — financial management: https://www.multirent.ca/services/#gestion-financiere
• The multiRent blog: https://www.multirent.ca/blogue/