Ontario HR Compliance · Federal Pay Equity Act
Pay Equity: Annual Statement, Maintenance Cycle and the Pay Equity Commissioner
Once a pay equity plan is posted, the ongoing duties are an annual statement to the Pay Equity Commissioner due each June 30 and a full maintenance update at least every five years, administered by the Commissioner's office inside the Canadian Human Rights Commission.
Posting a pay equity plan isn’t a one-time filing. Two ongoing duties follow it.
The first is an annual statement to the Office of the Pay Equity Commissioner, due on or before June 30 each year — June 30, 2025 was the first deadline for employers who posted their plan in 2024, and it’s June 30 of the year after posting for anyone who took an extension.
The second is maintenance: the plan itself has to be updated at least every five years. For employers who posted their initial plan by September 3, 2024, the first maintenance plan is due by September 3, 2029. Maintenance runs on ongoing annual data collection and a maintenance notice that precedes the updated plan itself.
The Pay Equity Commissioner administers and enforces the Act from inside the Canadian Human Rights Commission, which also houses the Accessibility Commissioner and conducts Employment Equity Act compliance audits — the same body sits across several of the federal equity statutes. Penalty exposure under the Act runs up to $30,000 per violation for employers with 10 to 99 employees, and up to $50,000 for employers with 100 or more.
This is general information, not legal advice; confirm the current annual-statement deadline and maintenance requirements at the Pay Equity Commissioner’s office before relying on them.
Source: Norton Rose Fulbright — Upcoming deadlines for complying with federal pay equity legislation ·
Also: Fasken — What's next for federal employers who have posted their initial pay equity plan
Last reviewed .
Confidence: Verified
Related notes
- 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.
- Pay Equity Plan: Posting Deadline, Extensions and Committee — Covered federal employers had to post a final pay equity plan within three years of becoming subject to the Act — September 3, 2024 for most — after a 60-day draft comment period, with a pay equity committee required for unionized or 100-or-more-employee workplaces.
- Administrative Monetary Penalties (Part IV): Framework and Baseline Schedule — Part IV of the Canada Labour Code sets administrative monetary penalties for designated violations, classified Type A through Type E and scaled by employer size, with a repeat-violation multiplier and a $250,000 statutory cap per penalty.
- 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.