The question every rental property owner eventually faces—whether they plan to handle maintenance themselves or hire contractors—is this: Do I need a licence from the Régie du bâtiment du Québec (RBQ) to perform, or have performed, maintenance or renovation work on my buildings?
Understanding the Exemptions
Property Owners, RBQ Licensing, and CCQ Competency Cards
Questions about licensing exemptions in Québec arise frequently—and for good reason. The regulatory framework is intricate and often requires a careful, case‑by‑case analysis. To simplify matters, let’s begin with the essential principle: a property owner may, in certain clearly defined situations, perform or have work performed without holding an RBQ licence. These exemptions, however, are limited and tightly regulated.
When Can a Property Owner Be Exempt from Holding an RBQ Licence?
If you can prove ownership of the building, you may carry out certain activities without an RBQ licence:
- Perform yourself the work listed in Schedule III.
- Hire employees to perform the same Schedule III work.
- Assign multiple Schedule III tasks to a single licensed specialized contractor.
- Have electrical work performed by a properly licensed electrician.
- Carry out Schedule II work for a total value of $20,000 or less.
Important: Electrical work can never be included in the Annex II cost limit.
If the work you intend to perform does not fall within these exemptions, you must either:
- Obtain a general owner‑builder contractor licence, or
- Hire a general contractor licensed by the Régie du bâtiment du Québec (RBQ).
What About the CCQ?
Once the licensing aspect is clarified, a second critical factor must be evaluated: the sector in which the work will take place.
In Québec, it is essential to remember that:
- New residential construction.
- Commercial construction.
- Industrial construction.
- Institutional contruction.
Are sectors almost always governed by the rules of the Commission de la construction du Québec (CCQ). This means that every individual performing the work must hold a valid competency card, and this applies to each trade involved in the project.
Even if you own the building, this does not automatically grant you the right to perform work in these sectors. Ownership does not override the requirement for proper CCQ certification.
Why So Many Nuances?
Because every project is unique. Factors such as:
- the nature of the work,
- the sector of activity,
- the contract value,
- the involvement of subcontractors,
- the type of building,
- and even the sequence of the work.
can influence whether an exemption applies. A seemingly minor change in scope can shift a project from exempt to fully regulated.
Need Clarification?
RBQ and CCQ regulations are technical and can be difficult to navigate. Before starting any project, it is wise to confirm your obligations to avoid fines, delays, or compliance issues.
If you would like a personalized assessment or need help determining your obligations, feel free to contact us. We can guide you to ensure your project complies with the law and proceeds smoothly
