Canada Pay Equity Act Compliance Guide
Most federally regulated employers that were subject to the Pay Equity Act when it came into force had to post their final pay equity plan by September 3, 2024 and file their first annual statement by June 30, 2025. Annual statements are due every June 30 afterward.
Preparing Data for Pay Equity Reporting in Canada
This guide summarizes Canada's Pay Equity Act, which requires federally regulated employers to proactively identify and correct gender-based wage gaps in predominantly female job classes.
For comprehensive guidance, refer to the Canadian Human Rights Commission resource: Employers and workplaces regulated by the Pay Equity Act.
Who Needs to Report: Canadian Pay Equity Act Requirements
The Pay Equity Act, which came into force on August 31, 2021, applies to federally regulated employers with an average of 10 or more employees. This includes:
- Federally regulated private and public-sector employers
- Parliamentary workplaces
- The Prime Minister's and Ministers' offices
Employers with fewer than 10 employees are not subject to the Act.
Canadian Pay Equity Act Deadlines
Employers are required to develop a pay equity plan within three years of becoming subject to the Act. For most employers subject to the Act when it came into force, key dates were:
- September 3, 2024: post the final pay equity plan.
- September 4, 2024: complete first pay equity adjustments, or start permitted phase-in.
- June 30, 2025: file the first annual statement.
- June 30 every year afterward: file annual statements.
- September 4, 2029: post the first revised pay equity plan for employers on the original timeline.
Employers that became federally regulated after August 31, 2021 or received extensions may have alternative deadlines.
What to Include in the Pay Equity Plan
Employers must develop a pay equity plan that includes:
- Identification of job classes.
- Determination of gender predominance for each job class.
- Evaluation of job value based on skill, effort, responsibility, and working conditions.
- Calculation of compensation for each job class.
- Comparison of compensation between predominantly female and predominantly male job classes of equal value.
- Increases and timelines needed to close identified pay equity gaps.
The plan must be posted in a prominent location accessible to employees, and employees must be notified of its availability.
How to Comply
Employers must:
- Establish a Pay Equity Committee when required. Committees are mandatory for workplaces with 100 or more employees, and for workplaces with 10-99 employees where some employees are unionized.
- Develop the Pay Equity Plan using the statutory job class and compensation comparison process.
- Post the Pay Equity Plan and notify employees.
- Make pay equity adjustments by the required date or phase them in where permitted.
- File Annual Statements with the Pay Equity Commissioner by June 30 each year after the final plan is posted.
- Maintain Records related to the pay equity plan and implementation for at least six years.
Penalties for Non-Compliance with Canadian Pay Equity Act
The Pay Equity Commissioner can enforce compliance through:
- Administrative Monetary Penalties: up to 50,000 for employers with 100 or more employees.
- Compliance Orders requiring specific actions.
- Public naming of non-compliant employers.
Related Resources and Country Guides
- Australia Gender Pay Gap Reporting - WGEA compliance requirements
- UK Gender Pay Gap Reporting - UK compliance requirements
- France Gender Equality Index - French compliance requirements
- Germany Pay Transparency Law - German reporting obligations
- EU Pay Transparency Directive - European Union requirements
- Compensation Glossary - Glossary of compensation and AI terms
External Resources and Authority Links
- Government of Canada Pay Equity - Official guidance
- Pay Equity Commissioner - Regulatory authority
- Pay equity dates and deadlines - Official deadline table
- Annual statement guidance - Annual statement filing
- Canadian Human Rights Commission - Human rights oversight
- Pay Equity Act - Legal framework
Frequently Asked Questions (FAQ)
What is the Canadian Pay Equity Act deadline?
Most employers subject to the Act from the start had to post their final pay equity plan by September 3, 2024 and file their first annual statement by June 30, 2025.
Do I need to report if I have 8 employees?
No, the threshold is an average of 10 employees for federally regulated employers.
Do I need to file an annual statement?
Yes. After posting a final pay equity plan, employers must file an annual statement with the Pay Equity Commissioner by June 30 each year.
Is a Pay Equity Committee mandatory?
Yes, for workplaces with 100 or more employees and for workplaces with 10-99 employees where some employees are unionized.
How often do I need to update my pay equity plan?
Plans must be updated and revised at least once every five years.
Where do I post my Canadian pay equity plan?
The plan must be posted in a prominent location accessible to all employees, with notification of availability.
For detailed information and updates, refer to the Canadian Human Rights Commission's guidance: Pay equity dates and deadlines.