OPSI - UNENACTED working proposal v308 | 2026-10-28T08:17:20+00:00 | Corpus 85 DRAFT GOVERNMENT REGULATION REGULATION RESPECTING BUILDING IDENTIFICATION AND ADMINISTRATIVE TRANSMISSIONS TO THE CENTRAL REGISTRY OF OPSI I - PURPOSE AND ADMINISTRATIVE SOURCES Section 1 | ART_RRCRGHS4601VNQEN | Version 5 This regulation is made by the Government under section 119.1 of the Act respecting land use planning and development, section 35.1 of the Fire Safety Act and section 111.1 of the Building Act, enacted respectively by sections 52, 53 and 55 of the Act. Its adoption and publication follow the Regulations Act; the Minister’s and the Order’s own powers remain separate. This Regulation governs transmission to the central registry of OPSI of information on covered buildings, permits and authorizations, demolitions, competent authorities and administrative triage keys. It applies to bodies covered by the Act respecting land use planning and development, the Fire Safety Act and the Act respecting fire safety practitioners. It also governs requests to identify missing buildings, authority-specific applicability declarations, and the procedure for consensus followed by resolution of administrative identification disputes. It determines no legal jurisdiction or new professional requirement. Documentary transmissions and mandatory EDF_ identifier associations under this regulation take effect for each building only when the region concerned is legally activated. The earlier administrative pre-registry contains neither fictitious EDF_ identifiers nor full reports. Section 2 | ART_PGQ6RPEAJLNQ9CM5 | Version 2 An authority primarily uses reliable administrative data it already holds. Where the same data can lawfully and reliably be obtained from another authorized administrative source, the registry avoids requiring duplicate transmission. This Regulation changes neither permit issuance criteria nor substantive building oversight responsibilities. II - PERMITS, OCCUPANCY AND DEMOLITION Section 3 | ART_DN63A5Z98XBSFQJV | Version 2 Where an initial permit authorizes construction of a new covered building, the issuing authority transmits, upon issuance and no later than five working days thereafter, through an administrative interface or secure API the permit identifier, date, category and description of the proposed building, known lots and addresses, issuer identity and any other reference essential for matching. The registry checks for duplicates, creates an “Authorized project” record, assigns a new EDF_ identifier and returns it in an acknowledgement to the authority. The information is transmitted to the competent authorities concerned and the registry at the same time, directly or through an integrated route confirming receipt. Where the issuing body is also the competent authority, one traceable transmission suffices. This period or mechanism runs for a region from its legal activation and imposes no new transmission under this regulation during the inactive phase; duties under other laws remain unchanged. Section 4 | ART_CDJ1UNQ9V0SYH2QM | Version 2 On receiving reliable administrative confirmation of completion or occupancy, the authority possessing the information transmits it within fifteen working days. The registry sets the state to “Active building”. An occupancy certificate, where one exists, may constitute this confirmation; property taxation or assessment-roll entry is supplementary evidence and not the primary trigger. Confirmation of construction or occupancy is communicated to the affected authorities and the registry through the same route, without duplicate reporting where the functions are combined. This period or mechanism runs for a region from its legal activation and imposes no new transmission under this regulation during the inactive phase; duties under other laws remain unchanged. Section 5 | ART_B0T5EMEGTRERF456 | Version 2 An authority cancelling a permit or confirming final abandonment of a project reports that fact within fifteen working days, together with any available administrative reason. The registry marks the project “Cancelled project”, retains its EDF_ identifier and prevents reuse. Cancellation or abandonment is communicated to the competent authorities through the same integrated transmission mechanism. This period or mechanism runs for a region from its legal activation and imposes no new transmission under this regulation during the inactive phase; duties under other laws remain unchanged. Section 6 | ART_90PSF9YMSAU1UNK0 | Version 2 An authority issuing a demolition authorization for a covered building reports the event within five working days; the record becomes “Demolition authorized” and remains in the monitored inventory. When demolition is actually completed and confirmed by an authority possessing the information, that authority transmits confirmation within fifteen working days. The state becomes “Demolished building — archived” without deletion of the EDF_ identifier or history. Demolition authorizations and confirmations are also communicated to the affected competent authorities through the same transmission route, reusing information already communicated reliably wherever possible. This period or mechanism runs for a region from its legal activation and imposes no new transmission under this regulation during the inactive phase; duties under other laws remain unchanged. Section 7 | ART_P4MXHE13L7PZPUYW | Version 2 An authority reports within fifteen working days any relevant administrative change to a previously transmitted authorization, including address, location, lots and descriptions needed to detect duplicates. A change does not automatically create a new EDF_ identifier. These administrative updates are transmitted to the competent authorities concerned or made available through the integrated route without redundant submission. This period or mechanism runs for a region from its legal activation and imposes no new transmission under this regulation during the inactive phase; duties under other laws remain unchanged. III - BUILDING IDENTITY AND MATCHING Section 8 | ART_YF3K9X234B378YES | Version 2 Transmission identifies each building separately on land containing several buildings and associates a single building with several lots as necessary. Available references are provided without artificially requiring a one-building-per-lot relationship. Section 9 | ART_YBNDM8MKYHJEMBS8 | Version 2 Complete reconstructions after demolition receive a new EDF_ identifier and a historical link to the old record. Extensions, renovations and conversions are matched with the existing EDF_ identifier unless physical and functional identity criteria establish a new building. Previous non-compliances are not automatically carried over. Section 10 | ART_8JVL1BEH1K83T6G8 | Version 2 The registry retains prior lots, addresses, available changes of ownership and other relevant references with their dates. When a collision, error or duplicate is detected, it preserves matching links, technical decisions and earlier identifiers without recycling any EDF_ identifier. IV - JURISDICTION AND TRIAGE KEYS Section 11 | ART_19CLJFZ321ZWW9BD | Version 3 Within thirty days after assuming, changing or ceasing jurisdiction, the authority declares its identity, the building EDF_ identifier, the regulatory domain, the nature and date of the event and, if applicable, the intermunicipal agreement or stated administrative basis. It may end its affiliation without naming a successor. A jurisdiction declaration is accompanied, where applicable, by a separate declaration indicating whether the building is subject to that authority’s filing or monitoring obligations in the field stated. The registry keeps each declaration separately and does not infer one authority’s declaration from another’s. This period or mechanism runs for a region from its legal activation and imposes no new transmission under this regulation during the inactive phase; duties under other laws remain unchanged. For the purposes of the functions under section 25 of the Act establishing the Order, the following requirements supplement this Regulation: Each competent authority may, within its lawful field, report and have a missing building identified without a recent permit, update its administrative information, declare whether a building is subject to filing or monitoring requirements within its own jurisdiction. The registry stores each authority’s declarations separately. These declarations neither create nor remove legal requirements and are not automatically inferred from a building’s type, address or cadastre. An authority may request correction of administrative boundaries, associations or information and the merger or subdivision of records where justified by the shared identity of buildings. A purely administrative association preserves existing building records. A genuine change in building identity may require new building records, without deleting or reassigning former ones and while preserving historical links. Where several authorities are attached to the shared identity concerned, a merger or subdivision affecting building records requires their consensus. If disagreement persists, the Régie du bâtiment du Québec determines the limited administrative identification dispute upon referral by an interested authority, in accordance with the Building Act. Pending that determination, existing records, filings and notices remain operational. The decision determines neither the authorities’ legal jurisdiction nor the applicability declarations each makes within its own field. Every municipality or other public authority legally issuing a permit or authorization for the construction or demolition of a covered building communicates the administrative events required by the Act establishing the Order or an applicable amending provision to the registry. That transmission allows creation of the official building record at initial authorization; its scope, time limits and procedures are determined by government regulation. It adds no condition to permit issuance. The Government may by regulation prescribe the time limits, information, electronic methods and receipt, correction and reconciliation mechanisms applicable to administrative transmissions and declarations by public authorities covered by the Act establishing the Order and corresponding amending provisions, including declarations of jurisdiction and administrative associations. Such regulation may not alter the legal allocation of jurisdiction or impose new general investigative, oversight or enforcement duties on the Régie du bâtiment du Québec. Section 12 | ART_GHJ3P8LL99BPSYQW | Version 2 The same EDF_ identifier may have multiple jurisdiction declarations, including across municipalities or regulatory domains. The registry does not automatically use the main doorway or 911 call-centre location to determine jurisdiction. Declarations do not grant or remove legal authority, and the registry does not decide disputes. Different applicability declarations by field or authority are not automatically a dispute: each authority remains responsible for its own declaration. The Régie’s limited administrative determination concerns shared record identity only, not those declarations. Section 13 | ART_F2CA3H3CM4UQK5Y8 | Version 4 Each authority declares a triage key from its own system, unique among buildings under that authority, linked to the EDF_ identifier and that authority’s AC_ identifier, and kept stable. Where an EDF_ identifier falls under several authorities, each retains its key and domain. Temporary absence of a key blocks no fire safety transmission. This period or mechanism runs for a region from its legal activation and imposes no new transmission under this regulation during the inactive phase; duties under other laws remain unchanged. Each registered competent authority has its own permanent AC_ identifier and must assign to each building under its jurisdiction an administrative triage key specific to that authority and linked to both its AC_ identifier and the building’s EDF_ identifier. The authority selects the key under its own administrative system; a key may not designate two buildings within that authority. The key remains stable and never replaces either EDF_ or AC_. Several authorities may each have their own triage key for the same building. For the purposes of the functions under section 25 of the Act establishing the Order, the following requirements supplement this Regulation: For each building, the registry determines the administrative recipients of notices: the legally competent authorities and, where the conditions under the Act establishing the Order are met, the Régie du bâtiment du Québec. Routing is calculated automatically from authority declarations and reliable administrative sources; it creates neither a new class of building nor a determination by the Order of legal jurisdiction. In the absence of a ground for routing to the Régie, notices are sent to the authorities lawfully entitled to receive them for each relevant regulatory area, subject to initial-integration rules. Supplementary routing to the Régie applies as soon as any of the following grounds is established for at least one relevant regulatory area: 1° “direct RBQ jurisdiction”: the Régie du bâtiment du Québec is itself legally the competent authority for the area concerned; 2° “institutional conflict”: the competent authority that would ordinarily receive the notice is also, directly or indirectly, the building’s owner, manager or operator, including where a municipality owns the building or an entity it controls administers it; an authority declaration or reliable administrative source is sufficient, without an additional inventory; 3° “no competent authority designated”: no competent authority is declared for an applicable area of an active building, or the previously designated authority has ceased to have jurisdiction without a declared successor; 4° “additional regulatory ground”: a situation prescribed by regulation of the Minister responsible for the administration of the Building Act (chapter B-1.1) under section 20. One ground affecting a single area is sufficient to trigger supplementary routing of notices to the Régie for the building. The registry nevertheless retains the separate authorities, declared areas of jurisdiction and administrative associations for each area: notices relating to other areas continue to reach their lawful recipients. This routing does not transfer legal jurisdiction to the Régie or displace a legally competent authority. During the initial 18-month period prescribed by the regulation made under section 25, a provisional lack of an authority designation in the initial inventory does not by itself cause mass routing of notices to the Régie. An actual serious non-compliance notice “requiring action” in an area with no designated authority nevertheless immediately triggers supplementary routing to the Régie, even during that period. The Régie’s direct jurisdiction and institutional conflicts are recognized without delay. Any change in conditions results in recalculation, without erasing previous grounds, transmissions or timestamps. For the purposes of the functions under section 29 of the Act establishing the Order, the following requirements supplement this Regulation: As soon as it is filed, every reportable notice is made available without delay to each legally designated authority, including the Régie du bâtiment du Québec in the cases provided for in sections 25 and 20. The registry initiates the regulatory notifications and reminders without requiring the professional to transmit the notice a second time in normal operation. The initial integration moratorium may not delay the routing of urgent notices to the Régie. Filing proves only receipt of the notice by the registry; it does not prove technical delivery of a supplementary notification, reading, or acknowledgment by a competent authority. Those events are tracked separately for each recipient, including the Régie under sections 13 and 14. The professional need not send the notice a second time during normal operation. This chapter imposes no duty on an authority to confirm reading or acknowledgment. The period stated in the notice does not suspend any immediate measures required, the powers of the competent authority or any other more stringent obligation applicable to the situation. Section 14 | ART_JAF4XXY72DPKQTCR | Version 3 Only the authority that assigned the key may request a change by dated, reasoned writing identifying the requester. The registry validates the origin and retains prior and new values, date and reasons in the permanent log, refusing changes requested by a different authority, an owner or a professional. A key entered in the registry may be changed only upon a written, dated and reasoned request from the competent authority that assigned it. The registry retains the former value and permanently records the new value, the reason, the date and the person making the change in the audit log referred to in section 14. Assigning a key does not, in itself, create, recognize or alter any legal jurisdiction. V - TRANSMISSION AND SECURITY Section 15 | ART_DLF69QQSZL6FR6YM | Version 2 Transmissions may be made through authenticated APIs or an administrative interface depending on the authority’s integration level, without routine manual entry when systems can exchange data directly. Reading, creation, administrative update and professional filing permissions remain separate. Section 16 | ART_6Z1WKZZBD6W6SVU3 | Version 2 Each event receives a timestamped acknowledgement, unique event identifier and validation result. An error produces actionable feedback and a means of retrying without loss or duplicate building creation. Corrections are logged without erasing initial messages. Section 17 | ART_BJCL691FPB0K3QNQ | Version 2 Authentication, least-privilege APIs, multifactor authentication for sensitive users, delegated authorization where necessary, confidentiality, audit logging, backups and disaster recovery are maintained under the registry regulations and applicable personal-information legislation. VI - INITIAL INTEGRATION Section 18 | ART_DMNEE1B6WJC2F34X | Version 2 Within twelve months of the operational start of initial integration, the registry progressively matches municipal inventories, property assessment rolls, cadastral data, permit files and legally available information from competent authorities. Each identified building receives an EDF_ identifier; duplicate records and multiple buildings on a lot are resolved by documented matching. The Order need not perform a physical census. This period or mechanism runs for a region from its legal activation and imposes no new transmission under this regulation during the inactive phase; duties under other laws remain unchanged. Section 19 | ART_L08HEPBUXSAWMXUA | Version 3 Authorities have eighteen months from the operational start of initial integration to declare progressively the active buildings under their jurisdiction and transmit their administrative triage keys. Before the deadline, a provisional lack of designation in the initial inventory does not mass-classify EDF_ identifiers as “EDF_ — RBQ”. After the deadline, EDF_ identifiers for active buildings without a designated authority in an applicable regulatory area follow the “EDF_ — RBQ” routing category under section 25 of the Act. Direct Régie jurisdiction and institutional conflicts are classified without delay. Even before that deadline, an actual serious non-compliance notice “requiring action” with no designated authority is immediately routed to the Régie on the same terms as a notice to a competent authority. The integration period does not prevent that routing. This period or mechanism runs for a region from its legal activation and imposes no new transmission under this regulation during the inactive phase; duties under other laws remain unchanged. Section 20 | ART_HNFT7AZY1GX2HLFA | Version 2 A competent authority may report or have a record created for an existing building omitted from the registry without supplying a new permit. Its request states available administrative references, location, declared jurisdictional field and any administrative triage key it holds. The registry searches for existing EDF_ identifiers and potentially matching records before assigning a new one. Uncertainty is handled through a traceable matching process. A professional may report a missing building during an urgent filing, which remains receivable. This period or mechanism runs for a region from its legal activation and imposes no new transmission under this regulation during the inactive phase; duties under other laws remain unchanged. Section 21 | ART_XLMHJ329C3N3KQYZ | Version 2 Each competent authority enters and updates, for buildings within its jurisdiction, a declaration of applicability or non-applicability for each regulatory field. It identifies the author, effective date, available administrative or regulatory reference and, on revision, the reasons for the change. The registry retains separate declarations from different authorities, including divergent ones. Their legal effect depends on applicable law and may not be inferred automatically from the address, cadastre, building category or presence of equipment. This period or mechanism runs for a region from its legal activation and imposes no new transmission under this regulation during the inactive phase; duties under other laws remain unchanged. Section 22 | ART_MV17WAK53BFFGRRK | Version 2 A competent authority submits requests to correct administrative boundaries or associations, or to merge or subdivide building records, identifying the EDF_ identifiers, purpose, reasons, available supporting administrative information and intended effects. Where a request would change the shared identity of a record within the jurisdiction of several authorities, the registry notifies each authority and obtains their express, traceable consent. Existing records and EDF_ identifiers remain operational during review. A mere administrative association does not in itself justify issuing new EDF_ identifiers. Section 23 | ART_ZJ1PQY0FBQ6BE3YS | Version 2 After a documented attempt at consensus and thirty days after the request was communicated to all concerned authorities, an authority may refer a persistent dispute on shared building identity alone to the Régie du bâtiment du Québec under proposed section 111.1 of the Building Act. The referral identifies EDF_ identifiers, authorities concerned, the request, remaining disagreements and representations already made. The Régie invites representations from affected authorities and issues a reasoned written determination within a reasonable administrative time. The procedure addresses neither legal jurisdiction nor each authority’s declared regulatory applicability. Section 24 | ART_ZFW9BGNGC2W8YAK0 | Version 2 The registry gives effect to documented agreements or the Régie’s administrative determinations while preserving the identity and history of each EDF_ identifier; necessary new identifiers are issued only for a genuinely new identity and never permit reuse of a previous EDF_ identifier. Decisions, dates, representations, links among records and changes in administrative affiliations are retained in permanent history. No dispute interrupts mandatory filings or notices. Section 25 | ART_47LPTFGC8SPZEP47 | Version 2 Permit, lifecycle event and jurisdiction transmissions use a secure API or administrative interface according to authorized permissions. The same event already obtained from a reliable lawfully authorized source need not be sent twice; acknowledgements and errors remain available to the authorities concerned. This period or mechanism runs for a region from its legal activation and imposes no new transmission under this regulation during the inactive phase; duties under other laws remain unchanged.