Introduction

Quebec’s move to CDAE-IA isn’t just about changing which activities qualify—it’s a complete shift in how you need to approach technical hiring, team structure, and employee certification. CFOs and CTOs must align their talent and funding strategies.

Switching from CDAE to CDAE-IA marks a pivotal moment for Quebec tech companies. While most conversations focus on the new AI integration requirements, the employee eligibility rules are just as crucial for how you build, organize, and retain your technical teams.

If your company claims over $100,000 in tax credits each year, your choices around employees directly affect your funding. Hiring the wrong roles, poor time tracking, or delays in certification can mean losing tens of thousands in credits. On the other hand, a talent strategy built around CDAE-IA rules helps you maximize both innovation and funding recovery.

Understanding the Six-Employee Minimum

CDAE-IA still requires at least six eligible full-time employees primarily dedicated to qualifying activities. This isn’t just a numbers game—it’s a strategic baseline that shapes how you build your team and allocate resources.

What counts as an “eligible employee” under CDAE-IA:

  • Employees spending at least 75% of their time on qualifying AI-integrated e-business activities

  • Individuals with valid employee eligibility certificates from Investissement Québec

  • Team members whose work is directly tied to developing, integrating, or improving AI-enabled systems

  • Staff working on activities covered by eligible NAICS codes (513211, 513212, 51821, 541514, 541515)

Who doesn’t count toward the minimum:

  • Contractors and consultants (no matter their technical skills)
  • Employees who spend most of their time on excluded maintenance tasks
  • Administrative, sales, or operations staff
  • Technical employees mainly working on internal IT systems instead of commercialized products

For smaller teams, losing even one eligible employee can put your entire CDAE-IA eligibility at risk. That’s why retention and backup planning are essential parts of your funding strategy.

The New Calculation: Salary Thresholds Instead of Caps

One of the biggest changes with CDAE-IA is how employee pay factors into your credit. The old $83,333 salary cap is gone, but now there’s a new exclusion threshold.

How the exclusion threshold works:

  • The first $18,571 of each eligible employee’s annual salary (indexed yearly) doesn’t qualify
  • Only the portion above this threshold earns tax credits
  • There’s no upper limit on eligible salary amounts

What this means for your strategy:

For an AI engineer earning $120,000 a year:

  • Excluded: $18,571
  • Eligible salary: $101,429
  • 2026 credit potential: about $30,429 (22% refundable + 8% non-refundable)

For a senior machine learning specialist earning $150,000:

  • Excluded: $18,571
  • Eligible salary: $131,429
  • 2026 credit potential: about $39,429

This new structure changes the economics of hiring. You get more value from hiring highly paid AI specialists than from spreading work among several junior developers. Removing the salary cap especially benefits companies competing for top technical talent in tight markets.

Hiring for CDAE-IA Eligibility

Focus on AI-Specialized Roles

With CDAE-IA, general software development roles no longer guarantee eligibility. Your hiring should focus on positions directly tied to AI integration:

High-value roles:

  • Machine learning engineers who develop and implement ML models
  • Data scientists building predictive analytics and intelligent systems
  • AI/ML architects designing systems that use neural networks and automated decision-making
  • MLOps engineers maintaining and optimizing AI infrastructure
  • Research scientists advancing AI capabilities in your products

Supporting technical roles:

  • Full-stack developers working on AI-powered features (not just routine maintenance)
  • Data engineers building pipelines that feed AI systems
  • DevOps specialists supporting AI model deployment and monitoring
  • Software engineers implementing AI-driven automation

Roles with limited or no eligibility:

  • General web developers working on non-AI features
  • IT support and internal systems administrators
  • QA testers doing routine testing (not AI model validation)
  • Project managers and product managers (unless they do technical work)

Write Job Descriptions for Certification Success

Investissement Québec looks at what employees actually do—not just their job titles. Your job descriptions, offer letters, and performance goals should clearly spell out AI-related responsibilities.

What to include in job descriptions:

  • Specific AI technologies the role will use (like TensorFlow, PyTorch, neural networks, NLP models)
  • A clear link to qualifying activities (for example, “develop machine learning models for our customer recommendation engine”)
  • The percentage of time spent on eligible vs. non-eligible work
  • Deliverables focused on AI integration, not just general software development

Vague descriptions like “develop software solutions” make certification harder. Be specific: “design and implement neural network architectures for predictive analytics” clearly shows eligibility.

The 75% Rule: Managing Time Allocation

Eligible employees must spend at least 75% of their time on qualifying activities. This simple rule gets complicated in practice, especially for roles with mixed responsibilities.

What Counts as Eligible Time

Your project must create new knowledge that advances science or technology. It’s not about using existing tech—it’s about building something truly new or improving existing capabilities beyond what’s currently known.

Qualifying activities include:

  • Developing AI models, algorithms, and intelligent automation systems
  • Integrating machine learning into existing platforms
  • Building data processing infrastructure that supports AI
  • Designing and implementing neural networks
  • Creating predictive analytics and decision-support systems
  • Conducting applied AI research that directly supports product development

Activities that don’t qualify:

  • Routine bug fixes and maintenance
  • Internal IT support and infrastructure not related to AI products
  • General admin tasks and meetings
  • Training not related to AI development
  • Sales, marketing, and business development

Best Practices for Time Tracking

Accurate time tracking is a must. During audits or certification reviews, you need to prove that eligible employees really spend 75% or more of their time on qualifying work.

How to implement this:

  • Use project-based time tracking with clear categories for AI and non-AI work
  • Choose timesheet systems that automatically check the 75% rule
  • Review time allocations quarterly to spot employees at risk of dropping below the threshold
  • Reassign tasks if someone is close to the 75% line
  • Keep detailed project descriptions that link work to eligible activities

For employees with mixed roles, consider restructuring so you have dedicated AI-focused positions. This can boost your credits and make documentation easier.

Certification Process: Navigating Investissement Québec

Organization Certification

Before any employee can qualify, your company needs an organizational eligibility certificate showing:

At least

75%

of gross revenue

from IT sector activities

At least

50%

of gross revenue

from eligible NAICS codes

75%

of gross revenue

from third-party services or applications used outside Quebec

  • Quebec establishment and the right corporate structure

This certificate proves your basic eligibility and must be renewed every tax year.

Employee Certification

Each eligible employee needs their own certificate from Investissement Québec. The application requires:

What you’ll need:

  • A detailed job description outlining AI-related duties
  • An employment contract or offer letter
  • An organizational chart showing the employee’s position
  • Project descriptions that connect their work to eligible activities
  • Time allocation estimates showing at least 75% qualifying work

Timing to keep in mind:

  • Initial applications take 6-8 weeks to review
  • Incomplete applications extend processing time significantly
  • Retroactive certification is possible but adds uncertainty
  • Filing early helps you avoid credit delays due to certification gaps

Strategic tips:

  • Renew your organizational certificate early in the fiscal year
  • Apply for employee certificates as soon as you hire
  • Keep a pool of pre-certified roles for quick hiring
  • Document everything as you go, not after the fact

Retention Strategy: Safeguarding Your Eligibility

Losing eligible employees creates two problems: it disrupts your operations and puts your funding at risk. If you drop below six eligible employees, you lose CDAE-IA eligibility until you rebuild your team.

Financial Incentives That Match Credit Value

Consider structuring pay to reflect the funding value employees bring:

If a senior AI specialist generates $40,000 in annual credits, their total value to your company includes both their technical skills and the funding they unlock. This supports offering competitive compensation that might otherwise seem high.

Career Growth Linked to AI Skills

Employees want to grow. Offering clear advancement paths tied to AI skill development helps you keep talent and maintain eligibility:

  • Training programs focused on advanced AI/ML skills
  • Conference attendance and ongoing AI education
  • Mentorship from senior AI experts
  • Opportunities to work on cutting-edge AI projects

These investments boost retention and deepen your AI expertise, making CDAE-IA qualification stronger.

Succession Planning for Key Roles

Don’t run with exactly six eligible employees. That leaves no room for turnover, leaves, or shifting to non-eligible work. A safer approach is to keep 7-9 eligible employees, so temporary gaps don’t threaten your eligibility.

How to Steer Clear of Common Mistakes

The Contractor Pitfall

Many tech companies rely on contractors for specialized AI work. This is a major CDAE-IA risk: contractors don’t count toward the six-employee minimum and their costs aren’t eligible for credits.

Strategic response

  • Convert key contractor roles to full-time positions when possible
  • Use contractors for short-term needs, but keep a core group of eligible employees
  • Remember: savings from contractors may be offset by lost tax credits

The Maintenance Exclusion

CDAE-IA specifically excludes routine maintenance and evolutionary work. Employees who spend a lot of time on bug fixes, system monitoring, patches, and incremental updates may not qualify.

Risk mitigation

  • Separate development teams from maintenance teams when you can
  • Rotate maintenance duties so no one employee exceeds the 25% limit
  • Clearly separate “maintenance” from “AI enhancement” in your project planning

Documentation Gaps

The most frequent reason for certification denial is insufficient documentation of AI-related work. Vague project summaries, missing time logs, or unclear job duties make it difficult to get approved.

Prevention strategy

  • Set up documentation standards before you start hiring
  • Train your managers on what’s needed for certification
  • Run internal audits every quarter to spot any gaps
  • Keep records up to date as you go, instead of trying to recreate them later

How CDAE-IA fits into your overall talent strategy

CDAE-IA requirements shouldn’t be treated separately from your broader talent approach. The most successful companies weave funding criteria into their overall people strategy.

Key ways to integrate:

Recruiting

Screen candidates for roles that are most likely to qualify for certification

Onboarding

Teach new hires about time tracking and which activities are eligible

Performance management

Make maintaining CDAE-IA eligibility part of employee goals

Organizational design

Organize teams to maximize both operational efficiency and funding opportunities

Compensation

Include the value of the credit in your total compensation planning

By integrating these elements, you can use funding requirements to strengthen—not limit—your talent strategy.

How Boast simplifies certification and tracking

Managing CDAE-IA employee eligibility means coordinating HR systems, time tracking, certification paperwork, and ongoing compliance. Boast’s platform automates these processes, and our experts guide you through Investissement Québec’s requirements.

Our system automatically tracks employee time against the 75% threshold, alerts you to certification renewal dates, and keeps audit-ready records. Most importantly, our Quebec tax credit specialists help you design your talent strategy to boost both operational performance and funding recovery.

Whether you’re building your first eligible team or fine-tuning your current structure, Boast helps you secure every available credit while staying fully compliant with changing rules.

Ready to get more from your CDAE-IA talent strategy? Connect with our team to review your current approach, find new opportunities, and set up systems that make eligibility management easy.