The introduction of Bill 17, entitled the An Act mainly to amend the Act respecting natural gas storage and natural gas and oil pipelines in order to provide a framework for underground reservoirs and certain pipelines (hereinafter “Bill 17”), marks a decisive milestone in the development of Quebec’s legal framework for the energy transition by filling the regulatory gap surrounding the use of the subsoil for emerging activities, such as geological carbon storage.
Alignment with Existing Canadian Frameworks
While not the first province to introduce such a bill, Bill 17 follows in the footsteps of similar measures adopted in other Canadian provinces. In fact, several Canadian jurisdictions have already enacted legislation to regulate the underground storage of natural gas and gas and oil pipelines, including Alberta, Saskatchewan, Manitoba, Ontario, British Columbia, New Brunswick, Nova Scotia, and Newfoundland and Labrador, as well as the federal government for certain matters falling under federal jurisdiction.
A Response to the Demands of the Energy Transition
Given that reducing greenhouse gas emissions alone is no longer sufficient to achieve carbon neutrality, Bill 17 implicitly recognizes the need for permanent carbon removal solutions and aims to provide a rigorous, safe, and predictable framework for the development of new strategic energy sectors.
This framework also makes Quebec projects eligible for the federal Carbon Capture, Utilization, and Storage Investment Tax Credit[1]. Corporations that implement such commercial projects will therefore be able to take advantage of this significant financial incentive.
This legislative direction aligns directly with the vision of certain local corporations, which promote carbon capture and storage as essential tools for fulfilling Quebec’s climate commitments. They also rely on the province’s geological, energy, and industrial strengths. In this sense, Bill 17 appears not only as a tool for protecting and governing Quebec’s subsoil, but also as a concrete lever enabling the transition from pilot projects to industrial carbon removal infrastructure.
Purpose and Scope of Bill No. 17
Bill 17 aims to modernize Quebec’s legal framework governing underground reservoirs in order to enable and regulate new uses related to the energy transition, particularly carbon storage[2]. It replaces the Act respecting the storage of natural gas and natural gas and oil pipelines with the Act respecting underground reservoirs and certain pipelines. The bill specifies that underground reservoirs and certain fluids naturally present beneath the surface, other than water, are part of the public domain, and that their exploration or exploitation is strictly regulated.
Regulation of Energy Activities and Sectors
Bill 17 establishes a mandatory licensing regime for the exploration and development of underground reservoirs, including geological carbon storage activities. These activities may only be carried out under conditions set forth by regulation, under the close supervision of the Minister, and remain clearly distinct from hydrocarbon-related activities, which remain prohibited in Quebec. The bill thus aims to enable the deployment of carbon storage as a tool for reducing greenhouse gas emissions, without calling into question previous legislative decisions regarding hydrocarbons.
More broadly, Bill 17 seeks to regulate the development of new strategic energy sectors, such as carbon storage and other fluids relevant to the energy transition, within a controlled, safe legal framework that is consistent with Quebec’s climate policy objectives. It assigns the government a central role in the planning, authorization, and oversight of these emerging sectors.
Strengthened Environmental and Governance Requirements
The bill strengthens the environmental and safety framework for carbon storage projects. It establishes strict standards for project operations, including site stabilization, closure, restoration, and long-term monitoring. After a carbon storage project ends, the minister remains responsible for post-closure monitoring to ensure the protection of health, safety, and the environment. Financial guarantees may be required to cover future risks and obligations.
Finally, Bill 17 provides for significant involvement by the state and municipalities in land management. Certain underground reservoirs may be reserved for the state or excluded from any activity, particularly in urbanized or protected areas. The government may also authorize pilot projects, particularly regarding carbon capture and storage, to test new technologies in a controlled setting.
The Impacts of Carbon Capture Projects
Carbon sequestration[3] is already being studied, and in some cases implemented, in Quebec, with several innovative projects currently underway. However, the changes introduced by Bill 17 raise questions about the environmental impacts of these projects.
The environmental assessments and monitoring mechanisms provided for are intended to regulate carbon storage. No permits may be issued in protected areas or national parks, and project implementation must comply with existing mechanisms. The regulatory framework remains incomplete, however, and will need to be clarified through the adoption of regulations following public consultations on the bill[4].
The Interaction of PL-17 with Federal Environmental Standards
In Quebec, when it comes to environmental standards, businesses in certain sectors are already subject to a dual approval system. Indeed, a single project may fall under both provincial and federal jurisdiction.
Projects covered by Bill 17 must first comply with the requirements set forth in this bill as well as those arising from applicable Quebec environmental laws. Subsequently, when the project involves an area of jurisdiction also governed by federal law, it must also comply with that law.
For example, a carbon capture project likely to impact a watercourse serving as a fish habitat must satisfy not only the permitting requirements set forth in Bill 17 and the general provincial environmental regime, but also the obligations imposed by the Fisheries Act, which is a federal law[5].
It will therefore be essential for corporations to clearly identify the elements covered by their carbon capture project in order to correctly identify all applicable laws and ensure compliance with both the Quebec and federal regulatory frameworks.
Consultation with First Nations and Project Acceptability
The implementation of such projects also has an impact on the First Nations present in the region. Consulting with them will be essential in the context of implementing Bill 17. Elsewhere in Canada, there are already examples of First Nations getting involved in the development of carbon capture projects. This is particularly the case in Alberta, where several First Nations are calling for additional environmental assessments for a large-scale project[6]. In Quebec, partnerships are also emerging in this field between First Nations and specialized companies.
In short, Bill 17 establishes a regulatory framework that promotes the development of carbon capture projects, which are essential in the fight against climate change. However, it remains crucial to support innovation while taking into account environmental impacts and consultation obligations with the affected First Nations[7].
[1] Félix Gagnon and Jérôme Labbé, “Quebec Seeks to Regulate Carbon Storage (French Only)” February 7, 2026, Radio-Canada Info, Online: Québec veut encadrer le stockage du carbone | Radio-Canada
[2] Bill 17 - An Act mainly to amend the Act respecting natural gas storage and natural gas and oil pipelines in order to provide a framework for underground reservoirs and certain pipelines
[3] For example: Deep Sky, “Thetford Mines,” online : Thetford Mines
[4] Alexis Riopel, “Quebec Introduces Bill on Geological Carbon Sequestration“ (French only), February 5, 2026, Le Devoir, online: Le gouvernement Legault dépose un projet de loi sur la séquestration géologique du CO | Le Devoir
[5] Fisheries Act (R.S.C., 1985, c. F-14)
[6] Louna Marchet, “Carbon Capture: 8 First Nations Call for a Federal Assessment,” (French only) November 17, 2025, Radio-Canada Info, online : Captage de carbone : 8 Premières Nations demandent une évaluation fédérale | Radio-Canada
[7] Deep Sky, “Deep Sky and the W8banaki Nation Sign a Landmark Framework Agreement for Carbon Removal Projects in Quebec,” (French only) December 17, 2025, online: Deep Sky et la Nation W8banaki signent une entente-cadre structurante pour les projets d’élimination du carbone au Québec
