Jean-Francois MIGNOT, A century of child adoption: a comparative analysis of legal frameworks, practices, and demographics in France and Québec (1923–2025), International Journal of Law, Policy and the Family, Volume 40, Issue 1, 2026, 2026

France first authorized child adoption in 1923, and Québec in 1924. How have the laws and practices surrounding child adoption evolved in these two French-speaking Western nations over the past century? This article presents a comparative analysis of legal, statistical, and institutional data from these two jurisdictions to answer this question. First, the article discusses the evolution of French and Québec laws governing adoption over the past 100 years, noting a general softening of conditions for both adopters and adoptable children. Next, the evolution of the number of children adopted nationally and internationally shows a relatively higher incidence in Québec compared to France. Finally, the article discusses two issues that have evolved in similar ways in France and Québec: increasingly open access to origins for adoptees and allowing same-sex partners to adopt as a couple since the beginning of the 21st century. Overall, these two civil-law jurisdictions have adapted adoption to a more liberal conception of children’s best interests (vs. the objective of protecting family property).

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