October 16, 2026: End of the Quebec Safety Code Transition Period (and Why the Extension Does Not Apply to Your FSP)

Chapter VIII, Building, of the Quebec Safety Code incorporates the 2020 National Fire Code of Canada with Quebec amendments. The regulation adopting it was approved by Order in Council 438-2025 on March 19, 2025, published in the Gazette officielle (official gazette) on April 2, 2025, and in force since April 17, 2025. The Régie writes, word for word, that the provisions "as they read prior to April 17, 2025, may be applied until the day preceding October 17, 2026." That day is Friday, October 16.

A single exception: Article 2.1.3.7, which covers the testing of integrated fire protection systems in accordance with standard CAN/ULC-S1001, benefits from a three-year transition period, until April 2028. Everything else in the chapter, including Section 2.8 on fire safety plans, transitions on October 17, 2026. Among the changes highlighted by the Régie itself is "compliance of fire safety plans with the Quebec Safety Code and their implementation."

On August 26, 2026, the Régie published a news release entitled "Extension of the transition period in building and electricity". Three regulations, coming into force on September 10, 2026. The first two extend the transition of the Quebec Construction Code by one year: the provisions of Chapter I, Building, prior to April 17, 2025, and those of Chapter V, Electricity, prior to March 26, 2026, remain applicable "provided that work began before October 17, 2027." These rules govern the construction and alteration of a building, and thus designers and contractors.

The third regulation amends the Quebec Safety Code. Its full text, published in the Gazette officielle du Québec of August 26, 2026 (Order in Council 1353-2026), consists of two articles. The first replaces paragraph 1 of the third paragraph of section 344 with: "the prior standard may be applied for a variable transition period, provided for by regulation, following the date on which the new standard comes into force." The second sets the coming-into-force date. No dates, no mention of Chapter VIII, no mention of October 17, 2026.

The memorial from the Minister of Labour to the Conseil des ministres (Cabinet), dated June 8, 2026, states it bluntly: the twelve-month extension amends section 6 of the regulation on the Quebec Construction Code, and "consequentially, it is also proposed to amend paragraph 1 of the third paragraph of section 344 of the Quebec Safety Code." Further on: "For the Quebec Safety Code, the amendment to section 344 must be made consequentially. There is no other option." Section 344 deals with the construction standards to which an existing building must remain compliant; it does not affect Section 2.8 or the transition end date of Chapter VIII set by Order in Council 438-2025.

Both codes came into force on the same day, April 17, 2025, with the same 18-month transition period. The announcement from the Régie mentions the three regulations in a single sentence, including the one for the Safety Code, under a headline about an extension. And the word "building" refers to both Chapter I of the Construction Code and Chapter VIII of the Safety Code. You have to open the actual texts to see that only the Construction Code receives a new date.

The reflex to adopt: when someone tells you that you have an extra year for your FSP, ask them for the text. The only regulation from August 26 that affects the Safety Code is a concordance paragraph, and the Régie's page on the Building chapter of the Safety Code still displays the date of October 16, 2026.

Since April 17, 2025, a fire safety plan may comply with either the former or the new edition. As of October 17, 2026, it must comply with the new one. In practice, the fire prevention officer inspecting your FSP relies on Section 2.8 of the amended 2020 NFC: the seven elements of Article 2.8.2.1 (procedures, supervisory staff, training, facility diagrams, drills, hazard control, inspection and maintenance), training of supervisory staff before they assume their responsibilities (2.8.1.2), the copy kept in the location agreed upon with the fire department (2.8.2.5), distribution to supervisory staff (2.8.2.6), posting of the emergency procedures in each floor area (2.8.2.7), and fire drills at the prescribed frequency (2.8.3.2). The details of each element can be found in our article on what the Code requires in an FSP.

An FSP reviewed at intervals of no more than 12 months, as required by the chapter, has normally already been updated to the 2020 edition over the past year. The issue arises for dormant plans: drafted in 2022 or 2023, never reviewed, with departed managers and replaced equipment. For those, October 16 is not a formality; it is the date after which the document describes regulations that no longer exist.

If you are expecting a prevention visit, our 30-point checklist covers these items in the order the fire prevention officer reviews them.

The obligation to have a fire safety plan depends on the building's use, not the size of the business. Article 2.8.1.1 specifically targets buildings containing an assembly, care, treatment, or detention occupancy, private seniors' residences, construction and demolition sites, certain storage areas, and locations where flammable or combustible liquids are stored or handled, as well as any building whose construction requirements already called for a plan. A municipal by-law or an insurer may require it elsewhere. The October 16 date applies to all these buildings, without distinction. And if you are hesitating between an FSP and an emergency response plan, the four-question test settles it in two minutes.

With Previo, the revision date, designated individuals, training, and the drill log live in the same place, with reminders before each deadline. The next code change will not catch you off guard.