As announced in our previous article, the new obligations of the Registraire des entreprises du Québec (REQ) came into effect on March 31. In fact, it is now mandatory to specify the date of birth of each active administrator and provide a valid government identification document with the name, surname and date of birth of the administrator; notably the Quebec health insurance card, licence or passport.
The REQ also took advantage of this change to improve certain aspects of the administrator information. These are discussed in the following procedure.
To meet these new obligations, you must file a current declaration or annual declaration with modifications.
Therefore, you will need to connect to the REQ services using the NEQ and the clicSéqur Express.
2. Select the option « Produire une nouvelle déclaration ».
3. Complete as usual the information for the declaration.
4. Go to the section « ADMINISTRATEURS », select the administration one at a time and click on « MODIFIER »
5. Complete the relevant administrator fields:
6. Complete your declaration as per usual.
We ran a test with a current update declaration and the publication of the information was released almost instantly.
We assume that the timeline when providing information via an annual declaration will be about the same.
Considering that the delays for publishing an annual declaration are usually longer than for the current update declaration and considering the management issue for the payment of the annual registration fees, we suggest that you fulfill the obligation by means of a current declaration before making the annual update without modification.
You will have to comply with these new obligations at the earliest when:
Since you will be collecting a certain amount of personal and confidential information on the administrators of the Syndicates and considering Bill 25, we urge you to take every precaution to ensure the security of these information:
Remember that this obligation applies to all companies registered with the REQ. Therefore, all directors of management firms will have to go through the same process for their own management company.
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