Insurance brokerage bookkeeping in Quebec

Quebec runs on a different structure than the rest of Canada. Firms and representatives are registered and supervised by the Autorité des marchés financiers (AMF) under the Act respecting the distribution of financial products and services (chapter D-9.2). Bill 92 amalgamated the Chambre de l'assurance de dommages (ChAD) and the Chambre de la sécurité financière into a single self-regulatory organization, the Chambre de l'assurance, effective 4 July 2025.

Where Ontario prescribes a filing and Alberta prescribes a deemed trust, Quebec prescribes the account and the register. Section 10 of the Regulation respecting the registration of firms, representatives and independent partnerships (chapter D-9.2, r. 15) requires a firm that receives or collects any amount on behalf of others to maintain a separate account and to deposit all such amounts in it forthwith. The regulation defines a separate account as an account opened at an institution whose deposits are guaranteed under the Deposit Institutions and Deposit Protection Act. The registration file itself includes a signed declaration about opening and maintaining that account, so the commitment is made at registration and carried forward as a condition of keeping it.

The Regulation respecting the keeping and preservation of books and registers (chapter D-9.2, r. 19) then tells you how to account for it. A firm must maintain and keep up to date, at its establishment in Québec, accounting books and registers for the transactions it effects, plus a register pertaining to the separate account if it collects money on behalf of others. Section 5 requires the accounting for the separate account to be kept separate and distinct from the general accounting, and to record every amount deposited in and paid out of it. Section 7 sets out what the separate-account register must contain, including the client's name, the contract number, the amount and object of the transaction, the date of the deposit or withdrawal, and the name of the recipient of amounts paid out. In practice that is a trust subledger with named counterparties, which is exactly what a broker management system should be producing anyway.

Retention is fixed rather than advisory. Books and registers are preserved for five years from their closing, information about the separate account contained in the accounting books is retained for at least five years after the last registration, and client records are preserved for at least five years from the last of the final closing of the record, the date the last service was rendered, or the expiry without renewal or replacement of the last product sold. On the reporting side, a registrant notifies the AMF in writing within 30 days of any change affecting the accuracy of the information it has filed, and transmits annual declarations to the AMF within 45 days of a request, including declarations about liability insurance and an updated list of the representatives through whom it acts.

Two Quebec-specific practicalities round this out. GST and QST are administered through Revenu Québec, and the applicable treatment depends on the brokerage's facts, so we configure the tax accounts from the treatment confirmed by your Quebec tax adviser. And a language note we would rather set upfront: Quebec operates in French and has French-language obligations that touch how a firm communicates and documents. We work in English and do not currently provide French-language reporting, so French-language filings and client-facing documents need to be handled on your side.