The Quebec privacy regulator reports that the Cour du Québec rejected Clearview AI's appeal of the 2021 order against it

Key takeaways

• The CAI says the court rejected Clearview AI's grounds against the December 2021 order.
• On jurisdiction, the CAI reports a real and substantial connection between Clearview AI and Quebec.
• The CAI says the court did not rule on the applicability of the order, treating that as a question of fact.

What did the Cour du Québec decide, according to the CAI?

The CAI's news item of 16 October 2026 says the court rejected the grounds Clearview AI presented. The CAI describes the company as having scraped billions of images from websites and social media to build a face database, and as selling police and other clients a facial-recognition search engine that compares an image against that database to find biometric matches.

The order under appeal dates from December 2021 and followed a joint investigation with Canadian counterparts, the CAI says. In the CAI's account, the failure to obtain consent before collecting personal information from third parties, and the lack of a serious and legitimate interest supporting the collection, were breaches of the private-sector Act (the CAI's term is the "Loi sur le privé"). The order requires Clearview AI to stop collecting personal information of Quebecers and to destroy their images and biometric identifiers.

The CAI lists four grounds the company raised: that Quebec laws cannot apply to an American company with no office, employee or client in Quebec since July 2020; an error of law on the absence of a serious and legitimate interest; the unconstitutionality of the consent provisions relied on, because of their effect on freedom of expression; and the unreasonableness and inapplicability of the order. The CAI reports that the court rejected the grounds presented.

Why does the jurisdiction finding matter to companies outside Canada?

The company's first argument was that Quebec law could not reach it. The CAI reports the court's answer in one line: "Elle conclut à l'existence d'un lien réel et substantiel entre Clearview AI et le Québec", with the result that the cited laws apply to the company.

The CAI's summary does not say which facts the court relied on or define the test beyond the phrase itself. The company said it had no Quebec office, employee or client since July 2020, and the court still found a connection.

What did the court say about legitimate interest and freedom of expression?

On interest, the CAI reports: "Elle confirme que la collecte d'images par Clearview AI ne répondait pas à un intérêt sérieux et légitime". It adds the reason it attributes to the court: the collection was done in breach of the law.

On expression, the CAI says the court concluded that Clearview AI did not have its freedom of expression unjustly limited by the consent requirements imposed by the private-sector Act. The news item gives no further reasoning on either point.

Does the ruling decide whether the order is applicable?

Not according to the CAI, which reports: "Elle ne se prononce pas sur l'applicabilité de l'ordonnance de la Commission, s'agissant d'une question de fait." The company had argued the order was unreasonable and inapplicable. The CAI describes the question as one of fact and says the court did not address it.

The news item does not say what steps, if any, follow against Clearview AI or whether further review is available.

What should privacy counsel and foreign AI vendors do now?

Treat this as a reported outcome to be confirmed against the judgment, not as a settled statement of the law.

• Open the Cour du Québec decision through the link on the CAI page and read the jurisdiction reasoning, which the news item does not set out.
• List any collection of images, face templates or other personal information about people in Quebec, including from public websites, and record the consent or other basis relied on.
• Do not rely on having no Quebec office, employee or client as the reason Quebec privacy law does not apply, until counsel has checked that position against the judgment.
• Check the order itself, which the CAI links as a PDF, for the exact obligations imposed on Clearview AI so as not to overstate them to clients.

What are the key dates and parties?

What we did not verify

What we opened: the CAI news item of 16 October 2026, in French, on 2026-10-25.

What we did not open: the Cour du Québec judgment (the link on the CAI page was not reachable for us), the December 2021 order, and any statement from Clearview AI. We have no judgment date, docket number or reasons, and did not check for further appeals.

What we do not claim: how the court applied the real and substantial connection test, that the order has been or will be enforced, or that the ruling reaches any company other than Clearview AI. French quotations are reproduced from the CAI page.

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