Pay equity dates and deadlines

All federally regulated employers in Canada are required to comply with the same four main obligations under the Pay Equity Act. But not all employers have to follow the same deadlines.

Federally regulated public sector employers and Parliamentary institutions

If you were a federally regulated employer when the Act came into force on August 31, 2021, these are your key dates and deadlines.

Action	Average number of employees 10 to 99^{Table note}¹	Average number of employees 100 or more^{Table note}¹
Post Pay Equity Act notice	by November 1, 2021	by November 1, 2021
Post final pay equity plan	by September 3, 2024	by September 3, 2024
Complete first pay equity adjustments	by September 4, 2024, or the day after the final pay equity plan is posted	by September 4, 2024, or the day after the final pay equity plan is posted
Phase in increases	by September 4, 2029	by September 1, 2027
Post revised pay equity plan	by September 4, 2029	by September 4, 2029
Post first annual statement	by June 30, 2025	by June 30, 2025

Federally regulated private sector employers

Action	Average number of employees 10 to 99^{Table note}²	Average number of employees 100 or more^{Table note}²
Post Pay Equity Act notice	by November 1, 2021	by November 1, 2021
Post final pay equity plan	by September 3, 2024	by September 3, 2024
Complete first pay equity adjustments	by September 4, 2024, or the day after the final pay equity plan is posted	by September 4, 2024, or the day after the final pay equity plan is posted
Phase in increases	by September 4, 2029	by September 1, 2027
Post revised pay equity plan	by September 4, 2029	by September 4, 2029
Post first annual statement	by June 30, 2025	by June 30, 2025

Alternative dates and deadlines

If you became a federally regulated employer after August 31, 2021, you still need to follow the four main obligations outlined above, but by following these alternative dates and deadlines.

Federally regulated public sector employers and parliamentary institutions (after August 31, 2021)

Action	Average number of employees 10 to 99^{Table note}³	Average number of employees 100 or more^{Table note}³
Become subject to the Act	on April 1 of the year after the fiscal year in which the average number of employees was between 10 and 99	on April 1 of the year after the fiscal year in which the average number of employees was 100 or more
Post Pay Equity Act notice	60 days after becoming subject to the Act	60 days after becoming subject to the Act
Post final pay equity plan	three years after becoming subject to the Act	three years after becoming subject to the Act
Complete first pay equity adjustments	by the day after posting the final pay equity plan	by the day after posting the final pay equity plan
Phase in increases	by the day after the eighth anniversary of the date on which the employer became subject to the Act (and five years after posting the final pay equity plan)	by the day after the sixth anniversary of the date on which the employer became subject to the Act (and three years after posting the final pay equity plan)
Post the final version of the revised pay equity plan	by the fifth anniversary of the day on which the employer posted the final pay equity plan	by the fifth anniversary of the day on which the employer posted the final pay equity plan
Post first annual statement	by June 30 of the calendar year after the employer has posted the final pay equity plan	by June 30 of the calendar year after the employer has posted the final pay equity plan

Federally regulated private sector employers (after August 31, 2021)

Action	Average number of employees 10 to 99^{Table note}⁴	Average number of employees 100 or more^{Table note}⁴
Become subject to the Act	on January 1 of the year after the calendar year in which the average number of employees was between 10 and 99	on January 1 of the year after the calendar year in which the average number of employees was 100 or more
Post Pay Equity Act notice	60 days after becoming subject to the Act	60 days after becoming subject to the Act
Post final pay equity plan	three years after becoming subject to the Act	three years after becoming subject to the Act
Complete first pay equity adjustments	by the day after posting the final pay equity plan	by the day after posting the final pay equity plan
Phase in increases	by the day after the eighth anniversary of the date on which the employer became subject to the Act (and five years after posting the final pay equity plan)	by the day after the sixth anniversary of the date on which the employer became subject to the Act (and three years after posting the final pay equity plan)
Post the final version of the revised pay equity plan	by the fifth anniversary of the day on which the employer posted the final pay equity plan	by the fifth anniversary of the day on which the employer posted the final pay equity plan
Post first annual statement	by June 30 of the calendar year after the employer has posted the final pay equity plan	by June 30 of the calendar year after the employer has posted the final pay equity plan

Important reminders on timelines and compensation increases

The Pay Equity Act lays out the rules all employers must follow. However, there may be certain situations when an employer or pay equity committee needs to ask the Pay Equity Commissioner for permission to change the way certain rules apply to them. The Pay Equity Commissioner can authorize, in certain circumstances, modified application of the Pay Equity Act.

In order to obtain permission to apply the Act in a different way, employers and workplace parties must make an authorization request. Please note that filing an authorization request does not extend the timeline to create a pay equity plan. Additionally, even if an authorization request is made to extend the timeline for posting the pay equity plan, and that extension is granted, any compensation increases are still due on the day after the three-year deadline. Employers who owe their employees increases will have to pay them a lump sum plus compounding daily interest, calculated as of the three-year deadline.