Executive Summary
		The Provincial Employment Roundtable is pleased to submit this brief to the House of Commons Standing Committee on Official Languages regarding the draft regulations for the Use of French in Federally Regulated Private Businesses Act (UFPBA).  While we support the federal government’s aims of protecting the use of French, particularly in communities with a significant French-language presence, we are concerned about the draft regulations and their potential impacts on Québec’s English-speaking community. The proposed regulations introduce a compliance system for federally regulated private businesses (FRPBs) that may have unintended negative impacts on the employment and employability of Québec’s English-speaking community, which is already facing significant employment challenges and economic exclusion. Chief among these concerns is the transfer of language compliance costs and responsibilities to private employers, who are incentivized to reduce risks and costs and may respond by limiting the hiring, training, or advancement of English-speaking employees to facilitate French-language compliance. The UFPBA regulations also offer an opportunity to establish an improved framework for the use of French in FRPBs in Québec; one that does not simply duplicate the Charter of the French Language, which has already been shown to have adverse impacts on the employment and employability of English-speaking Quebecers. We offer recommendations to improve the UFPBA draft regulations, with the hope of establishing a framework that will meet the stated objectives of true substantive equality between French and English in Canada while mitigating the negative economic impacts on linguistic minorities and other vulnerable communities.

We recommend that: 

• The UFPBA require FRPBs to allocate funding for French-language training for current and prospective English-speaking employees. Establishing a dedicated training requirement would help ensure that language acquisition is treated as a workplace skill-development issue rather than solely as a hiring prerequisite.
• The UFPBA includes a commitment to federal funding support to reduce the financial burden of providing language training. To support the first recommendation, the federal government could establish a Language Training Subsidy for FRPBs affected by the UFPBA. 
• The UFPBA establish an alternative hiring pathway that permits workers with low French proficiency to be hired, provided employers offer a French immersion program within a prescribed period.
• The draft regulations for the UFPBA amend the ‘grandfathering’ protection for employees “who have many years of service” by lowering the threshold of having worked “20 or more years with the same employer,” thereby ensuring that the needs of mid-career and younger employees are also considered and protected.
• That the grandfathering protection for existing employees be made portable across the federal private sector so that mature workers and workers with accepted exemptions can maintain labour market mobility. 
• That the UFPBA reduce the administrative burden imposed on FRPBs by amending requirements related to annual statements and triennial reports. This may include extending reporting intervals for annual certificates of registration and certificates of generalization of the use of French.