Warranty of Good Working Order: What Changes October 5, 2026

A consumer law that quietly resets your equipment

The moment a text carries the “consumer protection” label, a building manager’s instinct is to move on: that’s law for individuals, not for a commercial portfolio. With the warranty of good working order taking effect on October 5, 2026, that instinct is a miscalculation. This new Quebec legal warranty mandates six years of coverage on air conditioners and heat pumps, and it reshuffles the durability and repairability of every unit sold in the province — including the ones landing on the rooftops and in the mechanical rooms you manage. Understanding it means avoiding unpleasant surprises at purchase or at breakdown.

What is the warranty of good working order?

The warranty of good working order is a legal warranty created by Quebec’s Bill 29 on planned obsolescence. In force on October 5, 2026, it requires both merchant and manufacturer to repair — at no charge — a good that stops working normally, parts, labour and shipping included, for a period set by regulation: six years for an air conditioner or a heat pump.

Its full name spells out the intent: the Act to protect consumers against planned obsolescence and to promote the durability, repairability and maintenance of goods. It applies to new goods, whatever the brand or price, and coverage starts at delivery. Crucially, it does not erase other warranties. The warranty of fitness, the reasonable-durability warranty and the warranty against latent defects still apply in parallel, and the buyer can invoke whichever serves them best. It also adds transparency duties: the manufacturer must disclose the duration online before the contract is concluded, and the merchant must display it clearly, near the price.

Six years on a heat pump: what’s covered?

The mechanics are simple: if the unit fails within the covered window, the repair is free. That includes parts, labour and reasonable transport or shipping costs — three line items that, on a heat pump compressor, quickly add up to most of the bill. The merchant who sold or supplied the unit is bound to honour the warranty, and so is the manufacturer.

Two exclusions deserve a manager’s attention. First, the warranty does not cover normal maintenance service or the wear parts replaced through it: cleaning a coil, changing a filter or swapping a wear component stays on you. Second, it does not cover damage from abusive use. In other words, letting maintenance slide is not just risky for the equipment — it also weakens your position if a dispute arises. A documented preventive maintenance program remains the best insurance policy, legal warranty or not.

What it changes — and doesn’t — for a commercial portfolio

Here is the nuance the generic summaries gloss over. The warranty of good working order lives in the Consumer Protection Act, which governs consumer contracts. A company buying a heat pump for a commercial building is, as a rule, not entering a consumer contract: the legal warranty therefore does not apply directly. Pretending otherwise would be dishonest.

But three ripple effects reach your portfolio anyway. One: manufacturers now have to design, document and support their units to a six-year standard and make the information available — repairability across everything sold in Quebec rises with it. Two: for a residential rental building, the line between commercial use and a consumer contract is subtler than it looks, and deserves a legal opinion rather than a guess. Three: nothing stops you from contractually negotiating coverage that matches the new market benchmark — an easier argument now that the law has made it the norm for identical units sold to individuals. When it’s time to replace a commercial heat pump, the question “how long is the support and parts availability?” is no longer a courtesy: it’s a selection criterion.

Why is 2026 a turning point in Montreal?

The timing is no accident. Cooling demand keeps climbing across Greater Montreal with each summer heat wave, and heating electrification is pushing heat pump adoption — backed by the subsidy programs active this year. The result: a record volume of units is being delivered and installed right now, on both sides of the October 5 cutoff. Two identical units set on the same roof, one delivered in late September and the other in mid-October, will not stand on equal footing under this warranty.

For a manager tapping the electrification incentives — a landscape we break down in our piece on heat pump subsidies for rental buildings — the stakes are twofold: capture the subsidy and document the delivery date. The same holds for a commercial air conditioning project planned for the fall across Greater Montreal: shifting a delivery by a few days can, on a rental building, change which warranty regime applies.

Field case: the delivery date that was worth money

A manager of a small Greater Montreal portfolio — a few rental buildings and one commercial unit — was replacing a batch of aging wall-mounted heat pumps in the summer of 2026. The initial plan grouped every delivery “whenever the supplier can,” with no thought given to timing. Reviewing the file, one detail jumped out: half the units were due in the last week of September, the other half around October 10.

The fix fit in a sentence: treat the delivery date as data to manage, not a logistics coincidence. Deliveries destined for dwellings were rescheduled after October 5 to line those units up with the new regime, delivery documentation was kept systematically, and the purchase order was revised to require, in writing, the manufacturer’s warranty duration and parts availability. No repair was on the table that day — but the day a compressor quits in year four, the difference between “covered” and “on your dime” will have been decided that summer, by a single line on a calendar.

What a manager should check before October

The concrete step to take now costs nothing and comes down to three moves. First, flag the air conditioner and heat pump deliveries scheduled around October 5, 2026 and, where it matters for a dwelling, position them accordingly. Second, require in writing your suppliers’ warranty duration and parts-availability commitment — the law already forces them to post the former. Third, keep proof of delivery and stay current on maintenance, since that part stays on you and is what protects your recourse.

The warranty of good working order won’t turn a commercial building into a protected consumer, but it durably raises the bar for what a new unit in Quebec should deliver. At Montréal Combustion, we build this date and this durability logic into the equipment-replacement projects we support across Greater Montreal — so that a purchase decided this fall still holds up six years from now.