Ontario HR Compliance · Employment Equity Act
Employment Equity Act: The 100-Employee Threshold and Annual Report
Federally regulated private-sector employers and Crown corporations with 100 or more employees must analyze their workforce against four designated groups, maintain an employment equity plan, and file an annual report by June 1 — an obligation that doesn't apply at all below 100 employees.
The Employment Equity Act applies to federally regulated private-sector employers and Crown corporations with 100 or more employees — the Legislated Employment Equity Program, or LEEP — plus the federal public service, the RCMP, and the Canadian Forces. Below 100 employees, this Act doesn’t apply at all; it’s a hard threshold, not a phased one.
A covered employer has four standing obligations: survey the workforce to collect representation data on the designated groups, analyze that data to identify underrepresentation, review employment systems to find the barriers causing it, and maintain an employment equity plan with numerical goals to fix it.
The four current designated groups are women, Aboriginal peoples, persons with disabilities, and members of visible minorities. Since January 2021, pay-gap data for these groups is also reported and published on Equi’Vision.
The annual report is due June 1 each year, covering the prior calendar year, filed through the Workplace Equity Information Management System. The Canadian Human Rights Commission conducts compliance audits against it.
For an employer of 20 to 200 people, this obligation only bites once headcount reaches 100 — see Employment Equity Act: Reform Status for changes that are coming but not yet in force. This is general information, not legal advice; confirm current filing requirements at the Government of Canada’s employment equity pages before relying on them.
Source: Government of Canada — Legislated Employment Equity Program ·
Also: Government of Canada — Employment equity for private-sector employers and Crown corporations
Last reviewed .
Confidence: Verified
Related notes
- Employment Equity Act: Reform Status — A government-commissioned task force recommended adding new designated groups and updating terminology, and Ottawa has announced its intent to act on that, but as of mid-2026 none of it is in force — the four original designated groups remain the current law.
- Federal Pay Equity Act: Applicability and the 10-Employee Threshold — The federal Pay Equity Act applies to all federally regulated employers, public and private, with 10 or more employees, and requires them to proactively identify and close gender-based pay gaps rather than wait for a complaint — a different statute from Ontario's Pay Equity Act, with different mechanics.
- Canadian Human Rights Commission: Complaint Process and How It Connects to Equity Obligations — Discrimination complaints against federally regulated employers go to the Canadian Human Rights Commission, which can investigate, help settle, dismiss, or refer a complaint to the Canadian Human Rights Tribunal — the same Commission also administers the Pay Equity and Accessible Canada Acts.
- Accessible Canada Act: Employer-Size Thresholds and Deadlines — First-plan deadlines under the Accessible Canada Act were phased by employer size — June 1, 2023 for 100 or more employees and June 1, 2024 for 10 to 99 — and organizations with 9 or fewer employees have no plan or reporting obligation at all.