Montréal Placement Agency: Licence, Head Office and Establishments

Executive Summary

A personnel placement agency or temporary foreign worker (TFW) recruitment agency must hold a CNESST licence to operate in Québec ^[1]. The licence covers an activity and an entity, not a label attached to premises: the regulation defines a placement agency by its personnel leasing activities, meaning supplying employees to a client enterprise ^[2], whereas services delivered under a service contract do not require a licence, according to the CNESST ^[3]. Hybrid contracts and unclear cases should be classified with the CNESST before premises are chosen.

The application requires contact information for the head office and each establishment ^[2], and the licence must be displayed in a visible location at the head office and every establishment ^[4]. The official pages reviewed do not define these concepts for agencies or expressly address virtual offices, coworking spaces or homes: this report therefore concludes neither that a virtual office is sufficient nor that a private office is mandatory, and it does not claim that a post office box or a reserved day creates or eliminates an establishment. Instead, it offers a map of five roles (head office, establishments, interviews, records, correspondence), a matrix of four premises options and a list of written questions to ask the provider and the CNESST.

For budgeting purposes, the licence costs $1,087 in 2026, payable annually ^[5], with that amount indexed every January 1; the 2019 news release stated $890 ^[6]. The $15,000 security required of placement agencies is a guaranteed amount ^[7]; with a surety bond, only the premium, set by the insurer, is an expense, whereas providing security by cheque or money order requires paying out the $15,000. Taxes on premises are 5% (GST) and 9.975% (QST) ^[8].

When moving, the CNESST must be notified without delay ^[4], the REQ within 30 days ^[9], and Revenu Québec separately ^[10]. For any ambiguous situation, written confirmation from the CNESST, through its online information request service ^[11], should precede the signing of a lease or business address agreement. This study is not legal advice.

Introduction and Context

A Montréal founder preparing to open a personnel placement agency soon faces the question of which address and premises to choose. The answer depends less on the label attached to the premises (home, coworking space, enclosed office, virtual office) than on what the business actually does there and what the Commission des normes, de l’équité, de la santé et de la sécurité du travail (CNESST) requires it to declare. This report, prepared as of November 12, 2026, from official pages reviewed on that date, separates five roles that are often confused: the head office, establishments, interview location, records storage location and correspondence.

A personnel placement agency or temporary foreign worker (TFW) recruitment agency « doit obligatoirement avoir un permis valide délivré par la CNESST pour exercer ses activités au Québec » ^[12]. The Act respecting labour standards (LNT) prohibits operating such an agency without a licence ^[1], and a client enterprise cannot retain the services of an agency that does not hold one ^[1].

This guide is intended for agency founders in Montréal, small service firms considering personnel leasing and TFW recruitment agencies. It does not rank agencies or provide legal advice: the publicly accessible sources consulted contain no blanket authorization for agencies to use virtual offices, coworking spaces or homes. This report claims neither that a virtual office is sufficient nor that every agency must rent a private office; ambiguous cases should be resolved in writing with the CNESST.

Publisher disclosure. The site publishing this report, 2727coworking.com, offers workstations, private offices, meeting rooms, virtual offices and business addresses in Montréal: it is an interested party. None of this report’s data comes from its website; citations refer to public bodies, legislation or pages on which other providers publish information about their own offerings.

Define the Activity Before Choosing the Address

Services or Personnel Leasing

The licence is tied to an activity and an entity, not to a type of premises. The implementing regulation defines a personnel placement agency as an entity at least one of whose activities consists of « offrir des services de location de personnel en fournissant des salariés à une entreprise cliente » ^[2]. The CNESST clarifies the dividing line: « Il n’est pas nécessaire d’avoir un permis d’agence si les services sont rendus dans le cadre d’un contrat de service » ^[3], whereas in personnel leasing, « c’est l’agence qui fournit du personnel, mais ce personnel travaille sous la direction de l’entreprise cliente » ^[3].

Three scenarios help clarify a project, without replacing an assessment of the specific contract:

• Consulting or a service delivered to achieve a result. A firm that carries out an assignment with its own teams, under its own direction, falls under a service contract according to the CNESST page.
• Personnel leasing. As soon as the agency’s employees work under the client’s direction, the activity meets the regulation’s definition.
• Hybrid contract. Placement may be just one activity among others: the CNESST gives the example of a business that mainly provides consulting services. It also invites businesses to contact it when placement activity is not clearly mentioned in their classification ^[3].

The workplace alone does not settle the question: a service provider can work on the client’s premises without becoming a placement agency ^[13], because in personnel leasing, the client obtains the employee’s capacity to work ^[13]. The CNESST notes that a business engaged in both personnel placement and TFW recruitment must hold both licences ^[5]. TFW recruitment covers services that may include helping workers with the steps required to obtain a work permit and acting as a representative or intermediary for a client enterprise. At the federal level, the Temporary Foreign Worker Program specifies that agencies recruiting for other businesses are not employers ^[14], that employers are responsible for the actions of those recruiting on their behalf ^[14] and that some provinces impose specific requirements on recruiters ^[14]. Only personnel placement agencies must provide security.

Why This Classification Comes Before Choosing Premises

A firm that concludes it does not lease personnel has no agency licence to display; a firm that does, even as a secondary activity, must plan from the outset for the addresses required in the application, licence display and record keeping. Clients cannot retain an unlicensed agency and must ensure that their agency holds a licence ^[15]. When in doubt, the « Nous joindre » page mentions the online information request service ^[11].

Mapping Locations and Roles

What the CNESST Requires You to Declare

The licence application requires, among other things, « Coordonnées du siège social de l’agence et de chacun de ses établissements » ^[12], the NEQ, the business’s legal structure and contact information for the designated contact person. The regulation repeats these requirements: the application must contain contact information for the agency’s head office and each of its establishments ^[2]. In the CNESST pages reviewed, the terms “head office” and “establishment” are not defined for agency purposes, and the pages do not expressly address virtual offices, coworking spaces or homes. The terminology used by the Registraire des entreprises du Québec (REQ) offers a reference point, with one caveat: it serves the legal publicity of enterprises, not licensing.

REQ Terminology, for Reference

• Domicile. For a legal person, the domicile address is the head office address ^[16].
• Establishment. The REQ describes a « lieu au Québec où l’entreprise exerce des activités, comme : le siège social, les bureaux et les diverses succursales » ^[16]. The Act respecting the legal publicity of enterprises requires the declaration of establishment addresses, specifying the principal establishment ^[17].
• Elected domicile. This is the address of the person authorized to receive the enterprise’s documents for the purposes of the Act ^[16]. This is a correspondence role, and the REQ attaches no rule about the type of premises to it.
• Registration. Regardless of its legal form, a business must normally register with the REQ ^[18].
• Public disclosure. The free public register displays, among other things, establishment addresses ^[19], and registered information may be set up against third parties from the date it is entered ^[17].

This terminology does not automatically carry over to licensing. It shows that, in this register, the concept of an establishment refers to a place where activities are carried out; the CNESST remains the authority on whether a location is an establishment within the meaning of the regulation.

Licence Display, Licence Number and Records

The holder must « afficher votre permis ou une copie dans un endroit visible de votre siège social et dans chacun de vos établissements » ^[5], which the regulation describes as a legible display in a conspicuous place in each establishment ^[2]. The licence number must also appear on routinely used documents, including invoices, contracts and websites ^[2]. As for records, the agency must retain contracts with each client enterprise for at least six years ^[2], along with the related invoices.

In the pages reviewed, none of these rules specifies where documents must physically be kept or how a licence should be displayed in shared premises: these points should be confirmed and recorded in the agreement with the provider.

Table 1: Map of Locations

Table 1 separates the five roles and indicates what the publicly accessible sources say and what remains to be confirmed. These are not legal conclusions.

The entries under “Declaration to verify” are supported by official texts only for the head office and establishments; the other three roles rest on open questions, hence the final decision worksheet.

Examples of How Organizations Publicly Present a Location

Two organizations’ pages illustrate how a location can be presented, without allowing any inference about the eligibility of their addresses. A recruitment firm displays a licence number and a list of its offices under the heading « Permis agence de placement de personnel » ^[21]. Another states that its physical office is where it meets candidates and clients ^[22]. These are providers’ statements, not legal requirements.

A Caution About Mail and Post Office Boxes

Canada Post describes a post office box as « un compartiment verrouillé situé dans un bureau de poste » ^[23], used solely to receive items sent through an approved service ^[23]. Canada Post also presents it as a way to keep a home address private ^[24]. The REQ, for its part, specifies that a post office box cannot serve as an individual’s professional address ^[16]. None of these sources says that a post office box, or a booked office day, creates or eliminates an establishment: the question remains unresolved with respect to the CNESST.

Premises Selection Matrix

Four Options, One Assessment Framework

Table 2 compares four premises options using the criteria that matter for an agency: what must be declared, licence visibility, client and candidate access, confidentiality and the evidence to request. It sets out questions to ask, not determinations of eligibility.

Three observations emerge. First, none of the four options is presented as accepted or excluded by the official sources reviewed. Second, displaying the licence « dans chacun de vos établissements » is the most concrete constraint: an arrangement in which the agency cannot display its licence, or has no access, is the most vulnerable. Third, the Ville de Montréal specifies that the occupancy permit is tied to both the occupied establishment and its operator ^[25]: an address therefore should not be chosen without checking occupancy of the premises in the correct entity’s name.

Local Authorizations and Records Security

Montréal’s occupancy permit page contains conditions that vary by borough; which provisions apply must be checked with the relevant permit counter. The city advises confirming that the activity is permitted before renting or buying premises ^[25]. In terms of security, the law makes the business responsible for the information it holds ^[20], and the CAI specifies that when a third party stores information, the business remains responsible for its obligations in the event of an incident ^[27]. These texts do not discuss coworking; they establish the criterion to apply to the chosen premises.

BDC notes that municipalities generally oversee zoning ^[28] and that professional services may require enclosed offices ^[29]. The Chamber of Commerce of Metropolitan Montreal describes coworking as resources and services rented by the hour, day or month ^[30].

A mailing address serves the correspondence role, not the question “where does the agency carry out its activities?” Providers describe a virtual office as more than just a mailbox ^[31], with no workstation: the product is the address ^[32], while business domiciliation is the legal use of declaring that address as the business’s address ^[32]. The providers themselves recommend checking the situation with a lawyer or accountant ^[32] and verifying that the address is accepted by the relevant bodies ^[33]; some include a monthly meeting room booking ^[34]. If the agency meets candidates or keeps records elsewhere, those locations are the ones to assess for declaration purposes.

Written Questions to Ask the Premises Provider

This list is intended to obtain written answers before signing that can accompany the file. It applies to a home (landlord or syndicate of co-owners), coworking space, enclosed office or business address service.

• Right to display. Can the agency display its licence, or a copy, in a conspicuous place on the premises, and how?
• Authorized space. What specific space is covered (workstation, office or room number), and during which hours?
• Reception. How are candidates and clients received?
• Identification and documents. What documents does the provider request concerning the entity, designated contact person and officers? For a business post office box, Canada Post requires legitimate proof concerning the organization ^[23].
• Interview rooms. Can rooms be booked by the hour or day, and does the contract describe this use?
• Records storage. Is locked storage provided? Who has access to paper records and equipment?
• Subcontracting. Do third parties handle mail or destroy documents? A written agreement must specify the measures they are to take.
• Exit terms. What notice is required, how is mail forwarded, and how long can the address be retained after the contract ends?
• Proof of occupancy. Does the provider issue an attestation, lease or agreement in the applicant entity’s name?
• Municipal authorization. Who holds the occupancy permit for the premises, and in whose name?

These answers do not replace the CNESST’s answers; they document the right to display and the space actually available to the agency.

Authorization File: Documents, Designated Contact Person and Security

Application Contents

The CNESST lists the information to provide. A checklist is useful for preparation: one line per document, with a person responsible, a date and written confirmation.

• Entity. Legal structure and contact information for each officer.
• Designated contact person. Name, date of birth and contact information for the designated contact person. For a legal person, this person must be an officer ^[2].
• NEQ. The Québec enterprise number, mandatory for every business doing business in Québec, with exceptions ^[35].
• Resolution. A resolution authorizing the designated contact person to submit the application.
• Locations. Contact information for the head office and each establishment.
• Attestation de Revenu Québec. Valid at the time of application ^[36], then at all times for the licence to remain in force ^[36]; it can be obtained online and is issued immediately if the conditions are met ^[37].
• Security. For personnel placement agencies only.
• Payment. Fees must be paid for the CNESST to process the application, and the application is completed in MonEspace CNESST.

Missing or false information can lead to the licence being refused or revoked: the declaration of locations must be based on documents describing actual occupancy.

Employer Registration and Agency Licensing: Two Systems

An employer that hires at least one worker must register with the CNESST for occupational health and safety ^[38], within 60 days of the first worker’s first day of work, and register for source deductions with Revenu Québec ^[39]. These registrations do not replace the agency licence. The CNESST confirms this indirectly: closing an employer file does not automatically terminate an agency licence ^[5]. The sources consulted do not say that one is equivalent to the other, and this report does not assume so.

Security: The Guarantee and the Premium Are Two Different Things

According to the CNESST, a personnel placement agency licence application must be accompanied by security of $15,000 ^[7], an amount also set by the regulation ^[2]. The security must remain valid at all times throughout the licence term ^[7]. It may take the form of a surety bond issued in favour of the Commission, or a cheque, postal money order or bank money order ^[2]. The CNESST specifies that the bond « n’est pas une lettre de garantie » ^[7], and that it is obtained from an insurance company authorized by the Autorité des marchés financiers ^[7]. Changing the form of security after issuance requires at least 60 days’ written notice.

The $15,000 is therefore the guaranteed amount. With a surety bond, it is not an annual expense: only the premium, set by the insurer, is an expense. With security provided by cheque, postal money order or bank money order, however, the $15,000 is actually paid out. The CNESST pages consulted provide no premium amount.

Data Analysis: Initial and Annual Budget

Official Amounts

According to the CNESST, the agency licence costs $1,087 in 2026 ^[5]. It is payable annually in one instalment ^[5], and is adjusted every January 1. The regulation provides for this annual indexation ^[2]. Once issued, the licence has no expiry date and remains valid as long as the conditions for maintaining it are met.

An apparent discrepancy merits explanation. When the regulation was introduced, a 2019 government news release announced an annual cost of $890 ^[6], security of $15,000 ^[6] and licences valid for two years ^[6]. These details date from the November 2019 announcement, with an effective date of January 1, 2020 ^[6]. Today, the CNESST lists $1,087 for 2026 and no expiry date, while the regulation states that the licence is issued without a fixed term ^[2]. In 2020, a law firm reported fees of $1,780 for 2020, payable in two annual instalments ^[4], or $890 per year. The difference from $1,087 is consistent with annual indexation (the CNESST states that the cost is adjusted every January 1), although the publicly accessible sources do not allow each intervening year to be reconstructed. Anyone citing $890 or « deux ans » is therefore repeating the 2019 text.

Security, Insurer and Taxes

An insurer’s rate schedule, dated November 2024, lists a fixed price of $900 for two years for a CNESST bond ^[40]. It carries the English label « Recruitment Agency », which differs from the CNESST designation: the insurer must confirm that the line does refer to this security. It also provides for a minimum earned premium in the event of cancellation ^[40]. Another insurer states that the cost depends in particular on the bond type, term and risk ^[41]. Only a dated quote is authoritative.

For premises, GST of 5% and QST of 9.975% apply to the price of a taxable supply ^[8], and commercial real estate rentals are among taxable supplies ^[8]. The two taxes together total 14.975%.

Market Benchmarks for Premises

No premises prices are invented here. Three brokerages publish indicators for the third quarter of 2026 that are not comparable because their definitions differ:

• CBRE. Greater Montréal vacancy fell 70 basis points to 17.3% ^[42]. Its table gives downtown vacancy of 16.3%, net asking rent of $21.92 per square foot and gross rent of $44.74, compared with 18.1%, $16.66 and $31.23 in the suburbs ^[43]. Net rent excludes costs that gross rent includes ^[43].
• Cushman & Wakefield. Vacancy is beginning to stabilize ^[44], with average gross asking rent of $36.21 per square foot ^[44], a full-service rate ^[44].
• Avison Young. Total availability fell from 18.3% in the second quarter of 2026 to 17.9% ^[45], with average net asking rent of $20.13 per square foot ^[45].

These figures describe buildings leased over the long term, not the rental of a workstation or office in a centre; they indicate the order of magnitude of a traditional lease, for example for a permanent establishment.

Table 3: Price Benchmarks Published by Providers

Table 3 brings together prices that providers themselves advertise for virtual office, business address or private office options in Montréal. It does not rank the offerings: currencies, taxes, commitment periods and dates differ, and unknown fields remain blank. None of these prices establishes that an option is suitable for an agency.

The table shows the gap between a mailing address (a few dozen dollars per month) and a private office (more than a thousand dollars per month), and the lack of comparability between pages: none specifies what the provider permits regarding licence display or interviews, hence the written questions above.

Annual Cost Formula

The annual cost for an agency preparing its application breaks down as follows:

• Documented premises and services. Price of the premises, room or address service, with taxes explicitly stated (5% and 9.975%).
• Licence fees for each required category. $1,087 per licence in 2026; two licences if the agency carries out both activities.
• Quoted surety bond premium. Amount unknown until a quote is obtained; do not add the guaranteed $15,000 if the agency chooses a bond; security provided by cheque or money order requires paying out the amount.
• Records management. Cost unknown: storage, secure destruction.

(Hypothetical example) A placement agency carrying out only that activity and choosing a bond with the premium shown in the November 2024 schedule ($900 for two years, or $450 per year) would have $1,087 in licence fees and a $450 premium, for a total of $1,537 per year before premises, any applicable taxes and records management. This illustrates a calculation; it is not a quote.

Changing Premises: CNESST, REQ and the Register Separately

Moving or adding a workplace triggers several separate procedures that do not replace one another.

1. CNESST (licence). The holder must notify the CNESST without delay of any change to the information provided in the application ^[5], as the regulation states in similar terms ^[2]. The CNESST indicates that the service for updating a licence holder’s file is used to report, for example, a name change registered with the REQ, and that changes to the agency’s contact information are reported through another online service ^[5]. The pages reviewed specify no number of days for agencies.
2. CNESST (employer). For occupational health and safety insurance, reportable changes include a change of address for the business or an establishment. This is a separate system from licensing.
3. REQ. A registered business has 30 days to declare a change ^[9], under the Act respecting the legal publicity of enterprises, unless a shorter period is prescribed ^[17]. Filing a current updating declaration carries no fee ^[9].
4. Revenu Québec. Changing an address with Revenu Québec is separate from doing so with the REQ: the change must also be reported to the register if the business is registered there ^[10].
5. Ville de Montréal. A new occupancy permit is required, in particular, when the operator changes ^[25].
6. Register verification. The CNESST register provides access to the list of licensed agencies ^[51], by NEQ or by region or licence category. Agencies must ensure that the information entered is accurate ^[51].

Two special cases deserve attention. If the NEQ changes (merger, change of legal form), the CNESST states that the new entity must submit a new licence application ^[5], which is consistent with the licence’s non-transferable nature. And if the agency ceases operations, it must immediately notify the CNESST in writing; closing the employer file is not sufficient.

Candidate Records: Security, Destruction and Third Parties

General confidentiality obligations belong in a separate guide. For choosing premises, bear in mind that the business is responsible for the information it holds, must take appropriate security measures to protect it, and must destroy or anonymize it once the purposes for which it was collected have been fulfilled ^[20], to be reconciled with the six-year retention requirement for contracts and invoices. A third party receives information only under a written mandate specifying confidentiality measures ^[20]. An enclosed office with locked storage reduces exposure; a shared workstation calls for a clean desk policy; a mailing address service requires a written agreement.

Decision Worksheet and Questions to Ask the CNESST

Six-Step Decision Worksheet

This worksheet informs the consultation and choice of premises. It provides no opinion on eligibility.

Cautious option (a precaution, not a legal requirement). While awaiting the CNESST’s written response, favour a lockable private office, with the right to display the licence written into the lease or contract for every location where the agency actually carries out its activity, and use the mailing address solely for correspondence.

1. Classify the activity. Consulting or services delivered under your own direction, personnel leasing, a hybrid, or TFW recruitment. When in doubt, write to the CNESST.
2. List the actual locations and their roles. Head office, establishment, interviews, records, correspondence (table 1).
3. Choose the option according to the roles. Home, open coworking space, enclosed office or separate mailing address (table 2), keeping in mind that the licence must be displayed in each establishment.
4. Obtain the provider’s written answers. Right to display, space, access, storage, exit terms.
5. Complete the file. Documents, designated contact person, NEQ, Attestation de Revenu Québec, security for placement agencies.
6. Plan updates. CNESST without delay, REQ within 30 days, Revenu Québec and Ville de Montréal separately.

Questions to Ask the Authority

The questions below should be sent in writing, for example through the CNESST’s online information request service. The answers must be kept on file.

• Can premises in an open coworking space constitute the agency’s head office or an establishment for licensing purposes, and under what display conditions?
• Must an interview room rented occasionally (by the hour or day) be declared as an establishment?
• Can a virtual office or business address service address be declared as the head office when management works elsewhere?
• Can the correspondence address differ from the declared head office, and which address must be entered in the public register?
• Where must the licence be displayed in shared premises to be « bien en vue » and legible?
• Within how many days must an agency address change be reported?
• Who must provide proof of occupancy, and what proof is required?

Implications and Outlook

For founders and advisers. The address is part of the compliance file: the same contact information appears in the licence application, the public enterprise register and the agency register. A single, updated table of locations prevents discrepancies, and this report’s framework can accompany a start-up file without replacing legal consultation.

Volatility. The licence cost is adjusted every January 1, the Attestation de Revenu Québec must remain valid at all times, and official pages evolve. This report reflects the texts read on November 12, 2026; the regulation and CNESST pages should be reviewed before each decision.

Unresolved uncertainties. The publicly accessible sources do not define the head office or establishment for agencies; they do not expressly address coworking or business address services; they give no numerical deadline for reporting an agency address change; and a surety bond premium depends on a quote.

Frequently Asked Questions

What Licence Is Required for a Personnel Placement Agency in Québec?

A licence issued by the CNESST is mandatory to operate in Québec. It applies to personnel leasing; according to the CNESST, a business that only provides services under a service contract does not need one.

What Licence Is Required for Temporary Placement or TFW Recruitment?

Both types of agencies hold a licence; a business carrying out both activities holds both.

How Much Does an Agency Licence Cost in 2026?

The CNESST lists $1,087 for 2026, payable annually. The $15,000 security for placement agencies is a guarantee: with a bond, only the premium is an expense; with a cheque or money order, the $15,000 is paid out.

Where Must the Licence Be Displayed?

The CNESST requires a visible location at the head office and each establishment. How this applies in shared premises should be confirmed in writing.

Is a Private Office Required, or Is a Virtual Office or Coworking Space Sufficient?

The publicly accessible sources do not expressly require a private office and do not generally authorize virtual offices. The declaration covers the head office and each establishment; the CNESST pages consulted do not address coworking or business address services, and according to these sources, a post office box or a reserved day does not, in itself, create or eliminate an establishment. Confirm in writing with the CNESST.

What Should You Do When Moving?

Notify the CNESST without delay, declare the change to the REQ within 30 days, inform Revenu Québec, then verify the accuracy of the register.

Conclusion

Choosing premises for a personnel placement agency in Montréal starts with the activity, not the label attached to the premises. The CNESST licence is tied to an entity and activities; the application requires contact information for the head office and each establishment, and the display requirement applies to the head office and every establishment. A home, open coworking space, enclosed office and separate mailing address differ in what they allow the agency to display, whom they can accommodate and what they can protect, and each calls for written answers from the provider.

The budget distinguishes the licence cost, any surety bond premium, premises and their taxes, and records management; the guaranteed amount must not be confused with a premium. Address changes are handled separately with the CNESST, the REQ, Revenu Québec and the city. In any ambiguous situation, the CNESST remains the authority to consult in writing before signing a lease or business address agreement.