Bonjour Petryk,
Let me put things in perspective:
The FQAS was created after a Coroner's special inquest was made in the deaths of many divers.
These deaths occured after divers certified in the warm clear waters of the Carribean died in the cold dark waters of Quebec. It was evident their training lacked in the particularities of the northern environment.
Acknowledging this, the government asked the scuba industry to prepare a special curiculum.
Every diver learning to dive in Quebec receives this particular training and gets the certification.
My dauther, for her open water cert, had to wear a 14 mm wet suit (7/7) and three finger mitts.
The dives were held in a quarry with water temp of 40 degrees at 25 feet . (In June)
So, to dive in Quebec , you ase supposed to have this certification, somewhat like you need a cave cert to dive at Ginnie Springs.
Now for enforcement: the most I have heard is that an inspector has been around a few popular dive sites, once or twice a year, to give information. No one, to my knowledge, has had any fine imposed because he did not have the certification.
I heard that the card was required by a fill station in the lower St-Lawrence region. Probably because that place has pretty advanced diving and many have died there.
As for my own experience: I received my first training in Jamaica. Back home I wanted to keep on diving and I contacted a local instructor (He teaches the DIR fundamentals but he is not from GUE or FQAS.)
All my training dives were done in the St-Lawrence river in the Thousand Island region of Ontario. I don't have a FQAS cert. I have never had problems getting fills in Montreal and no one asked me for the card in Quebec.
I understand that divers from outside the province simply have to show their ID and confirm they are familiar with cold water, low vis diving.
I hope this helps.
PS: I am not interested in spending the $125.00 needed for my FQAS cert upgrade (It costs only about $15.00 when you take an open water course)