CNESST obligations for self-employed workers and micro-businesses

Who must register with the CNESST — and when

Any employer hiring at least one worker (full-time or part-time) with an establishment in Québec must register with the CNESST, within 60 days of the first worker's first day of work — registration is possible up to 30 days before. Late registration triggers penalty fees (CNESST).

Two nuances that matter for very small structures: the obligation also applies when you hire a dependent self-employed worker whom the CNESST considers a worker, and volunteers and executives are not automatically covered — optional coverage exists. In other words, a truly solo self-employed worker has no mandatory registration, but the first hire changes everything.

19 or fewer workers: the health-and-safety action plan

Under the reform in force since October 1, 2025 (the permanent LMRSST regime), establishments with 19 or fewer workers must prepare, apply and annually update a written health-and-safety action plan. Employers have one year from October 1, 2025 (or from the establishment's creation) — i.e. by October 1, 2026 for existing establishments (CNESST; AOHS, s. 97.1).

A health-and-safety liaison officer (ALSS) must also be designated by the workers, and must complete CNESST-determined training within one year of designation — on paid time, at the Commission's expense. The ALSS makes written recommendations; the employer must respond within 30 days (CNESST).

20 or more workers: the prevention program

Establishments with 20 or more workers must prepare, apply and annually update a prevention program, set up a joint health-and-safety committee and designate a health-and-safety representative (RSS). Committee meeting frequency is set by agreement; absent one, the regulation imposes 4, 6 or 9 meetings per year by activity level, with at least one meeting per quarter. Committee members, including the RSS, must obtain a minimum one-day training attestation within 120 days of designation (deadline extended by six months by regulatory amendment), and the employer must draw up and keep continuously up to date a register of contaminants and hazardous materials present in the establishment (CNESST; RMPPÉ, ss. 19 and 31; AOHS, s. 52).

Under both regimes the update is annual: the prevention program (20+) and the action plan (19 or fewer) must each be reviewed every year.

The psychological-harassment policy

A psychological-harassment prevention and complaint-handling policy has been mandatory for all Québec employers since January 1, 2019. Since September 28, 2024 (Bill 42), it must include prescribed minimum content — risk identification and control methods, training and information programs, conduct at work-related social events, a complaint-and-report process including the sexual-conduct component — and employer prevention obligations cover harassment from any person, including clients and suppliers. Since October 1, 2025, the policy must be integrated into the establishment's prevention program or action plan (CNESST).

On the horizon: sexual violence in the workplace

The Regulation respecting measures to prevent or put a stop to a situation of sexual violence is final: published in the Gazette officielle on May 27, 2026, it comes into force on May 27, 2027 — except the training provisions (ss. 4–6), in force on May 27, 2028. It sets minimum measures for all workplaces regardless of size or sector, around two axes: information/training and a complaint-and-report process (Gazette officielle, May 27, 2026).

Minimum wage: the current rate

Since May 1, 2026, Québec's minimum wage is $16.60/hour (general rate) and $13.30/hour for tipped employees (Gouvernement du Québec; CNESST). The next adjustment is expected on May 1, 2027 (annual cycle).

Where to start

1. Hiring your first person? Register with the CNESST within 60 days — it's the first obligation that lands.
2. Existing establishment with 19 or fewer workers: your written action plan must be in place by October 1, 2026, with an ALSS designated by the workers.
3. Bring your harassment policy up to the Bill 42 minimum content and integrate it into your action plan or prevention program.
4. Put two dates in your calendar: May 27, 2027 (sexual-violence regulation) and the annual review of your action plan.