Ontario HR Compliance · Federal Pay Equity Act
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.
Covered employers had three years from becoming subject to the Pay Equity Act to establish and post a final pay equity plan — for most, that meant September 3, 2024, the next business day after the legislated August 31, 2024 date. Before the final plan, a draft has to be posted for a 60-day employee comment period.
Employers that are unionized, or that have 100 or more employees, must develop the plan through a pay equity committee rather than unilaterally: at least three members, at least two-thirds of them representing the employees the plan covers, with at least one member selected by each bargaining agent where the workforce is unionized.
Compensation increases required by the plan are payable from the day after it’s posted — September 4, 2024 for most employers. An employer that couldn’t meet the deadline could request an extension through the Pay Equity Commissioner’s Pay Equity Portal, but the increases stay retroactive to September 4, 2024, plus interest, regardless.
The federal public service itself is running behind this timeline: the Treasury Board Secretariat received its own three-year extension, granted by the Pay Equity Commissioner on August 19, 2024, and will post its final plan by August 31, 2027, covering roughly 270,000 Core Public Administration employees. That’s a signal about enforcement posture at the top of the federal system — it doesn’t change the deadline for a private-sector employer.
This is general information, not legal advice; confirm current deadlines and extension status at the Pay Equity Commissioner’s Pay Equity Portal before relying on them.
Also: Norton Rose Fulbright — Upcoming deadlines for complying with federal pay equity legislation
Last reviewed .
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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: 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.
- 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.
- 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.