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Pay Equity Commissioner's message
It is with great honour that I present to Parliament my 2024–2025 Annual Report entitled: “Pay equity compliance: Carving the path forward.”
Studies show that pay equity contributes to reducing income inequality, improving workplace culture, and driving economic participation and growth. It corrects wage disparities and values work fairly, regardless of gender. Closing the gender wage gap is crucial for prosperity, innovation, and social cohesion. As we look to building a stronger Canada and a stronger economy, pay equity plays a determinant role – where earnings serve as a marker of economic wellbeing and represent Canada's position on gender-based discrimination and injustice.
Canada's Pay Equity Act takes a modern, proactive approach to addressing pay inequality.
Reactive, complaint-based models place the burden on an employee to identify, challenge, and prove instances of inequality and the existence of barriers in their workplace. Fear of retaliation, a lack of resources, power imbalances and limited access to information were all barriers in themselves.
Canada's Pay Equity Act puts the responsibility on employers to assess their compensation practices, identify inequality and unfair practices, and then take concrete action. The work my Office does and the resources we provide ensure that the respect for worker's pay equity rights is part of organizational accountability and wage fairness.
Over the past year, my Office has continued to expand the guidance resources available to employers, to raise awareness and facilitate compliance with the Act. We have spoken to employers and unions across Canada, to share knowledge and to hear first-hand about the challenges people face as they move through the process, so that my Office can best support them. This year saw a steep rise in the number of formal disputes submitted for adjudication – and each decision I made builds the jurisprudence, helping to carve the way forward for future interpretation and application of the Act.
My Office also turned our attention to non-compliance with the Act. This past year, we developed an Annual Statement Portal, to streamline employer's annual statement submission obligations. We also introduced an audit framework and an enforcement framework that includes Administrative Monetary Penalties. Notifying employers early of these imminent compliance tools serves to motivate employers to prioritize compliance now, rather than face penalty actions in the future.
And we are seeing the wheels of change beginning to turn – momentum is building across sectors. Our data shows that more and more employers are aware of their obligations and are taking steps to embed pay equity into their compensation infrastructure. While the path forward may include challenges for all involved, the number of organizations committed to getting this right is growing.
I am committed to ensuring that pay equity is an embedded and permanent business practice in Canada. Our role as a regulator is to support workplace parties in their pursuit of wage equality: by offering clear guidance, ensuring compliance, and reinforcing the principle that equitable pay is a human right. A commitment to respecting that right will contribute to building a stronger Canada.
Sincerely,
Lori Straznicky
Federal Pay Equity Commissioner
Pay equity in Canada by the numbers
Text version of Graph 1
three linked circles:
- In 2024, women in Canada earned 87¢ for every 1$ earned by men
- That is equivalent to a wage gap of 13% between men and women
- This gap is even larger for Black, Indigenous, and other racialized women, and women with disabilities
Formal disputes
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Formal disputes - Text version
Two graphic strips:
- 2024-2025 = 77 received
- 2023-2024 = 6 received
7 disputes were closed distributed as follows:
- 3 resolved through decision
- 4 were withdrawn
Authorization requests
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Authorization requests - Text version
Two graphic strips:
- 2024-2025 = 465 received
- 2023-2024 = 21 received
331 resolved applications distributed as follows:
- 322 fully granted
- 1 in part
- 8 denied
Requests for information
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Requests for information - Text version
Two graphic strips:
- 2024-2025 = 679 received
- 2023-2024 = 401 received
664 requests for information resolved
Monitoring and promoting compliance
Timeline of progress
In 2024–25, our work at the Office of the Pay Equity Commissioner was focused on responding to an increase in requests for guidance from employers and ensuring they had the support and clarity needed to comply with the Pay Equity Act.
To help employers with their compliance obligations, the Office issued updates and reminders to employers via newsletters, used the communications features of the Pay Equity Portal, and developed an Annual Statement Portal to receive submissions.
From developing new resources and tools, to making rulings that clarify jurisprudence for all going forward, the Office is committed to adopting solutions that help ensure workplace parties have what they need to meet their obligations.
Looking ahead to 2025–26, the Office will focus its efforts on engaging with stakeholders, enforcing compliance with the Act with new tools at its disposal, as well as rendering decisions and resolving disputes.
Raising employer awareness
This year, a significant milestone occurred as federally regulated employers faced the first major pay equity deadline for posting their final pay equity plans. A key part of the work of the Office of the Pay Equity Commissioner is to help employers comply with their obligations under the Act. This impending deadline triggered a marked increase in engagement with the Office, as employers sought clarity and assistance around their obligations.
Of the contact made with the Office, there was a 2,000% increase in authorization applications. While 21 requests were made in 2023–24, this number climbed to 465 in 2024–25. The majority were requests for an extension of the posting deadline (85%), which indicates a widespread need for flexibility during this initial complex implementation phase. Of the 465 received, the Office resolved 330 applications—by granting 320 fully, one in part, and denying eight. The rapid adjudication of these cases was due in large part to newly introduced internal workflow processes to ensure timely responses.
The Office received a 69% increase in information requests. In 2023-24 401 requests were received, compared to 679 requests this fiscal year. The highest number of requests came primarily from employers (52%), which indicates that regulated entities are proactively seeking to understand and meet their obligations. Many inquiries centered on the pay equity plan process (35%) and the handling of disputes (32%). This shows a growing understanding of compliance requirements and a willingness to act transparently within the Act's regulatory framework.
As a result, the need to provide guidance and support to employers as they navigate complying with the Act is greater than ever.
Providing guidance to workplace parties
Throughout 2024–25, the Office of the Pay Equity Commissioner prioritized the development of practical tools and guidance resources for workplace parties. The resources provide knowledge, guidance, and support to promote proactive pay equity compliance across Canada's federal employment landscape. Each of these tools also helps to complement our Pay Equity Portal, where users can directly communicate with Pay Equity Officers.
Online course
Last year, in collaboration with Université TÉLUQ, a free online course was launched to help employers with the creation of pay equity plans and annual statements, and the calculation and implementation of compensation increases. This year the course was updated to bring even more value to participants. In 2023-24, 573 people enrolled in the course. This year, an additional 941 participants registered. This enrollment of more than 1500 people highlights the need for employer support to complete their regulatory obligations.
Publications
This year, the Office expanded its publications series of Interpretations, Policies and Guidelines, by adding four new publications and four additional notice templates. These additional resources address compensation adjustments, posting extensions, and phase-in period guidance. A comprehensive employer reference guide was also made available online to support employers in meeting their regulatory obligations and deadlines.
Engagement
The Office continued to be highly active in its engagement efforts, participating in multiple events and engaging close to 300 different stakeholders. Some notable engagements were the Pay Equity Commissioner's involvement at a meeting of the National Joint Council, and with the Air Line Pilots Association of Canada. She also addressed international audiences on the topic of Canada's pay equity regime at the Swedish Gender Equality Conference.
The Commissioner also spoke to representatives of federally regulated partners like the Association of Federally Regulated Employers – Transportation and Communications (FETCO), the Atlantic Provinces Trucking Association and the Canadian Labour Congress. Stakeholder engagements like these are not only beneficial to employers – it also allows the Office to learn about sector-specific challenges.
The Office also regularly engaged with the Tri-Partite Working Group—comprising over 40 organizations. The working group provided valuable feedback that helped in the development of guidance resources and the Annual Statement Portal. This reciprocal engagement, together with stakeholder engagement efforts, demonstrate the Office's commitment to being user-centered in its compliance facilitation activities.
Providing clarity through decisions
The Pay Equity Commissioner's decisions taken in 2024–2025 played a key role in helping to further define interpretation of the Act. Part of the Commissioner's mandate is to make decisions and resolve disputes when it comes to how employers implement the Act or when there are disputes between workplace parties. With an increase in cases received, and an increasing complexity in cases, each carefully weighed decision has served to clarify legal interpretations, address ambiguity, and set precedent in any future disputes. The decisions of the Pay Equity Commissioner are publicly available on CanLii.
There were 77 formal disputes filed this year, up from just six in the previous fiscal year. The disputes received included complaints, objections, and matters in dispute. The Office closed seven disputes in total this year: three disputes were resolved through formal decisions, while the remaining four were withdrawn.
When speaking with workplace parties, the Office heard that there was ambiguity around the Act's nuanced terms. In response to this, the Pay Equity Commissioner's decisions clarified the definitions and interpretations of the Act. These rulings carve the path forward in how the Pay Equity Act is applied. The Commissioner's decisions create jurisprudence, guide compliance efforts and help to reduce uncertainty in future scenarios.
As pay equity evolves in federal workplaces, these foundational decisions help to define the framework to ensure that there is fair and consistent implementation of the Act. They also ensure that as new disputes arise, workplace parties can rely on established precedent as they work towards the shared goal of achieving a workforce that receives equal pay for work of equal value.
Looking ahead: identifying and addressing non-compliance
In the future, the efforts of the Office of the Pay Equity Commissioner will increasingly prioritize enforcement and accountability for employers. As more and more employers cross the milestone of posting their final plans, the Office's focus will shift from education and facilitation to monitoring and enforcing compliance with the Act.
Annual statements
In June 2025, most employers will have a deadline to submit an annual statement, disclosing the outcomes of their pay equity plan. Employers will have to provide detailed reporting on job class compositions, compensation outcomes or planned compensation increases, and overall implementation progress of their plan.
In anticipation of this upcoming milestone, in 2024–25, the Office launched a dedicated Annual Statement Portal. This portal will make it easier for employers to manage and access their annual statement submission through a single, centralized system. It also minimizes the administrative burden on employers as they meet their regulatory obligations.
Audit function
A first iteration of our Audit Framework was introduced this year at an event hosted by the Office. The framework will set the direction for conducting compliance audits. The planned audits will assess how well employers are meeting their regulatory obligations, while also helping to identify ongoing or systemic issues. The event was attended by 31 organizations and their representatives.
To support the audit program, in the last year, the Office developed a detailed list of employers containing their key demographics, such as industry category, employer size, and geographic location, along with contact information. This tool details engagement history and enables strategic targeting and informed follow-up, to increase the efficiency and effectiveness of the audit program.
The Office is continuing to develop our audit function and implement feedback from stakeholders, with the planned launch of the audit program expected to take place in 2025-26.
Administrative monetary penalties
In June 2024, new Regulations Amending the Pay Equity Regulations Administrative Monetary Penalties (AMPs) and Technical Amendments came into force. These newly introduced penalties help to underscore the gravity of an organization's non-compliance. The Office has been working with internal partners and other federal regulators to develop policies and put into place the procedures needed to operationalize an AMP regime. Under this regime, the Pay Equity Commissioner will have the authority to fine employers for violating the Pay Equity Act or its regulations. This enforcement tool is expected to launch in 2025–26.
About us
The Pay Equity Act
The purpose of the Pay Equity Act is to proactively address gender-based discrimination and inequities in the pay practices and systems of diverse federally regulated employers.
The Act applies to federally regulated private and public sector organizations, parliamentary workplaces, and the Prime Minister's and ministers' offices with an average of 10 employees or more. In total, the Act applies to approximately 5,000 federally regulated employers and 1.4 million employees.
The Act does not currently apply to the territories (Yukon, Northwest Territories, Nunavut), or Indigenous governing bodies, including First Nations governments. Pay equity in these workplaces is still protected under section 11 of the Canadian Human Rights Act or territorial legislation. Employers with an average of fewer than 10 employees also remain subject to section 11 of the Canadian Human Rights Act.
Who we are, what we do
The Office of the Pay Equity Commissioner is part of the Canadian Human Rights Commission, and it supports the Pay Equity Commissioner, Lori Straznicky, in carrying out her duties and functions under the Act.
The Office works to promote pay equity and provide support and tools to these organizations so they can fully realize pay equity in their workplaces.
The responsibilities of the Office of the Pay Equity Commissioner include:
- monitoring and promoting compliance
- offering assistance to workplace parties, including in relation to complaints, objections and disputes, and deciding any matter or application over which the Commissioner has jurisdiction
- developing tools and resources to help employers meet their timelines under the Act
- educating and informing workplace parties of their rights and obligations under the Act
- undertaking and publishing research related to pay equity matters
- engaging with stakeholders and provincial counterparts
Annual reports
Pay Equity
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