Paid medical leave in the federal jurisdiction: employer perspectives

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Executive Summary

Introduction

Methodology

Findings for Quantitative Analysis

Industry and Demographic Characteristics

The options for the sectors had a wide variety ranging from broadcasting to banking. Most of the respondents were in the trucking (55.8%)^{Footnote 3}, followed by air transportation (15.2%) and by feed, flour, seed, and grain (5.3%). Table 1 shows the distribution of respondents across sectors.

Table 1: Respondent sector distribution

Sector	Percent	N
Air transportation, including airport-related activities	15.2%	43
Rail transportation	1.8%	5
Trucking (excludes courier and postal services)	55.8%	158
Courier or postal services	1.1%	3
Maritime transportation, including port-related activities	3.9%	11
Banking	0.4%	1
Broadcasting	3.2%	9
Telecommunications	4.6%	13
Feed, flour, seed, and grain (e.g., grain elevators, feed and seed mills, feed warehouses, grain-seed cleaning plants)	5.3%	15
First Nations band councils and Indigenous self-governments	3.5%	10
Pipelines	0.7%	2
Other public sector (i.e., federal government Crown corporations or shared-governance organizations not classified elsewhere in this list)	2.5%	7
Other private sector (e.g., uranium mining, oil and gas extraction in the territories)	2.1%	6

The number of employees at organizations also had a wide range, from less than 4 employees to over 10,000. Most organizations had fewer than a hundred employees (69.3%). Figure 1 demonstrates the distribution of employee numbers.

273 respondents

Figure 1: text version

Number of employees	Number of organizations
1 to 4	17
5 to 19	66
20 to 49	64
50 to 99	39
100 to 299	39
300 to 499	15
500 to 999	8
1,000 to 2,499	9
2,500 to 9,999	7
10,000 or more	8

Note: X-axis demonstrates the number of employees in organization and Y-axis demonstrates the number of organizations corresponding with the number of employees.

Most of the organizations had no collective bargaining agreement in place (76.4%; Figure 2). Of the ones who had a collective bargaining agreement (N = 56), some agreements were in place for fewer than 10 percent of their employees (n=6, 9.8%), while others covered 61 percent or more of their employees (n=37, 60.7%).

Figure 2: text version

Organizations with or without collective bargaining agreements	Answer in percentage
Yes	20.7%
No	76.3%
Don't know	3.0%

Note: "No" indicates no collective bargaining agreements; "yes" indicates that at least some of the employees had collective bargaining agreement.

Impact on Business Operations

Financial

Most organizations stated that the introduction of 10 medical leave days with pay:

• Did not lead to the organization hiring new employees to cover for unexpected absences (76.8%; while 23.3% answered that it has led to an increase in hiring; Figure 3). Further details are provided in the qualitative analysis section.

222 respondents

Figure 3: text version

Belief that medical leave has led to hiring new employees	Number of respondents
Yes	52
No	150

Note: The difference between the total number of respondents (222) and the combined number of “Yes” and “No” responses (202) corresponds to the number of “Don’t know” responses to the question.

• Further, when asked how much of their payroll was dedicated to covering staff absences due to paid medical leave in 2024, respondents stated that approximately 12.1% (SD = 12 percentage points; only 18 respondents) of their total payroll spending was used to cover absences due to the legislation.

Administrative

Most organizations believe that the introduction of 10 medical leave days with pay:

• Has led to some employees viewing the 10 days of medical leave with pay as an entitlement to be used fully every year, regardless of medical necessity (63%, while 26.1% think that this is not the case, Figure 4)

237 respondents

Figure 4: text version

Belief that some employees see medical leave as an entitlement	Number of respondents
Yes	149
No	62

Note: The difference between the total number of respondents (237) and the combined number of “Yes” and “No” responses (211) corresponds to the number of “Don’t know” responses to the question.

Majority believe that the introduction of 10 medical leave days with pay:

• Has led to some employees using medical leave with pay for non-medical reasons (43.9%, while 28.9% do not think this is the case; Figure 5).

227 respondents

Figure 5: text version

Belief that some employees use medical leave for non-medical reasons	Number of respondents
Yes	100
No	65

Note: The difference between the total number of respondents (227) and the combined number of “Yes” and “No” responses (165) corresponds to the number of “Don’t know” responses to the question.

Majority believe that the introduction of 10 medical leave days with pay:

• Did not lead to more employee complaints about coworkers using this leave for non-medical reasons (47.8%; while 37.9% think that it has led to an increase in complaints; Figure 6).

223 respondents

Figure 6: text version

Belief that some employees complain about coworkers using this leave for non-medical reasons	Number of respondents
Yes	84
No	107

Note: The difference between the total number of respondents (223) and the combined number of “Yes” and “No” responses (191) corresponds to the number of “Don’t know” responses to the question.

Majority believe that the introduction of 10 medical leave days with pay:

• Did not reduce the number of employees coming to work sick (45.1%, while 35.5% do think that there has been a decrease in sick workers; Figure 7). More details on reasons are given in the qualitative analyses section.

223 respondents

Figure 7: text version

Figure 7: text version

Belief that medical leave with pay reduced the number of employees coming to work sick	Number of respondents
Yes	79
No	101

Note: The difference between the total number of respondents (223) and the combined number of “Yes” and “No” responses (180) corresponds to the number of “Don’t know” responses to the question.

Staffing

Majority believe that the introduction of 10 medical leave days with pay:

• Has led to greater difficulty in forecasting staffing needs such as understaffing due to unexpected absences or overstaffing to plan for potential unexpected absences (53.3%; while 36.7% percent think that this is not the case; Figure 8).

225 respondents

Figure 8: text version

Belief that medical leave has led to difficulty in forecasting staffing needs	Number of respondents
Yes	120
No	83

Note: The difference between the total number of respondents (225) and the combined number of “Yes” and “No” responses (203) corresponds to the number of “Don’t know” responses to the question.

Majority believe that the introduction of 10 medical leave days with pay:

• Has led to an increase in extra work for employees covering absent coworkers (54.2%; while 34.7% think that this is not the case; Figure 9). More details on reasons are given in the qualitative analyses section.

224 respondents

Figure 9: text version

Belief that medical leave with pay has caused extra work for employees covering absences	Number of respondents
Yes	121
No	78

Note: The difference between the total number of respondents (224) and the combined number of “Yes” and “No” responses (199) corresponds to the number of “Don’t know” responses to the question.

Workforce Impacts

Majority believe that the introduction of 10 medical leave days with pay:

• Has led to difficulties in completing essential tasks more often (54.6%; while 37.4% do not think that is the case; Figure 10).

226 respondents

Figure 10: text version

Belief that medical leave with pay has caused difficulties in completing essential tasks	Number of respondents
Yes	123
No	85

Note: The difference between the total number of respondents (226) and the combined number of “Yes” and “No” responses (208) corresponds to the number of “Don’t know” responses to the question.

Majority believe that the introduction of 10 medical leave days with pay:

• Did not disrupt serving customers, clients, or supply chain partners due to increased employee absences from the use of medical leave with pay (47.1%, while 42.2% answered that there have been disruptions due to the legislation; Figure 11). More details on reasons are given in the qualitative analyses section.

222 respondents

Figure 11: text version

Belief that medical leave with pay has caused disruptions to services	Number of respondents
Yes	93
No	105

Note: The difference between the total number of respondents (222) and the combined number of “Yes” and “No” responses (198) corresponds to the number of “Don’t know” responses to the question.

Perceived Changes Post 2022

Most of the respondents stated that employee use of medical leave with pay has increased since December 1, 2022 (62%) while 28.2% did not think that there has been a change. When asked specifically about certain times of the year, responses indicated an increase in the use of medical leave with pay on workdays adjacent to regular days off compared to other days. For example, this could include a greater-than-average increase on Fridays or Mondays among employees who typically work Monday to Friday. These results can be seen in Table 2.

Table 2: Perception on the increase of medical leave with pay since the legislation

Times of the year	Yes	No	Don't know
The "Holiday Season" (Christmas Day [December 25], Boxing Day [December 26], and New Year's Day [January 1]).	102 40.6%	110 43.8%	39 15.5%
One or more other holidays (e.g., Good Friday, Canada Day, Thanksgiving Day)	93 37.5%	114 46.0%	41 16.5%
Workdays adjacent to regular days off compared to other days.	122 49.4%	81 32.8%	44 17.8%

Respondents indicated that currently full-time employees take 5.7 (SD = 3.1) days of medical leave with pay on average in a year, and they indicated that employees used to take 3 (SD = 2.8) days of medical leave with pay prior to the legislation. Figure 12 shows the distribution of the number of days that employees take as medical leave with pay within a year after the legislation.^{Footnote 4} Figure 13 demonstrates the same information prior to December 1, 2022.

Figure 12: text version

Days used as medical with pay by employees	Percentage of employees
0 days	22%
1 to 3 days	21%
4 to 6 days	17%
7 to 9 days	16%
10 days	19%
More than 10 days	5%

Figure 13: text version

Figure 13: text version

Days used as medical with pay by employees	Percentage of employees
0 days	42%
1 to 3 days	32%
4 to 6 days	15%
7 to 9 days	4%
10 days	5%
More than 10 days	2%

Collective Agreements and Union-Management Relations

Since the introduction of the legislation, most organizations have not updated their collective agreements (49.1%) while some have (43.3%; Figure 14). The majority has not experienced issues between management and collective bargaining unit(s) due to the 10 days of medical leave with pay requirements (56.6%) while others stated that they have experienced issues (37.7%; Figure 15). Since the no stacking update, most organizations have experienced conflict with collective bargaining unit(s) regarding the application of medical leave with pay and its interaction with existing benefits in collective agreements (60%), while others have not 35% (Figure 16). However, it is important to note that only 20 respondents answered this question.

53 respondents

Figure 14: text version

Updated collective agreement since the legislation	Number of respondents
Yes	23
No	26

Note: The difference between the total number of respondents (53) and the combined number of “Yes” and “No” responses (49) corresponds to the number of “Don’t know” responses to the question.

53 respondents

Figure 15: text version

Experiencing issues between management and collective bargaining units due to the legislation	Number of respondents
Yes	20
No	30

Note: The difference between the total number of respondents (53) and the combined number of “Yes” and “No” responses (50) corresponds to the number of “Don’t know” responses to the question.

20 respondents

Figure 16: text version

Experiencing conflicts with collective agreement due to the no stacking rule	Number of respondents
Yes	12
No	7

Note: The difference between the total number of respondents (20) and the combined number of “Yes” and “No” responses (19) corresponds to the number of “Don’t know” responses to the question.

Comparison of perceptions towards the legislation based on sector

To compare the perceptions of the legislation by sector, it was necessary to combine sectors into three categories: trucking (trucking and other road transportation but excluding courier and postal); (other) transport (air, rail, maritime); and Other industries (courier and postal; banking; broadcasting; telecommunications; feed, flour, seed, and grain; First Nations band councils; other public sector; and other private sector). This was done due to sample size constraints. Note that there are a few businesses (at most four of 158 respondents) included in trucking that are in other road transportation industries (e.g., bus companies); otherwise, the sector is composed of trucking companies.^{Footnote 5}

Results indicated that other sectors struggled less with completing essential tasks^{Footnote 6} (Figure 17), dealing with staffing needs^{Footnote 7} (Figure 18), and disruptions to serving customers^{Footnote 8} (Figure 19).

There were no statistically significant sectoral differences for employees coming to work sick, use of medical days for non-medical reasons, employees complaining about non-medical use of sick days, seeing the medical days as an entitlement, new employee hiring, or dealing with extra work for covering absences. These comparisons were done using Chi-square test.

Figure 17: text version

Belief that medical leave with pay has caused difficulties in completing essential tasks	Yes	No
Transport	23	19
Other	16	29
Trucking	84	37

Figure 18: text version

Belief that medical leave has led to difficulty in forecasting staffing needs	Yes	No
Transport	22	18
Other	15	29
Trucking	83	36

Figure 19: text version

Belief that medical leave with pay has caused disruptions to services	Yes	No
Transport	17	21
Other	9	32
Trucking	67	52

Comparison of perceptions towards the legislation based on company size

The company sizes were also grouped as 1 to 20 employees (small), 20 to 100 employees (medium), and more than 100 employees (large).

There were statistically significant differences between organizations based on size, which will be further explained below for small, medium, and large enterprises for the following questions: on the number of sick employees coming to work^{Footnote 9} (Figure 20), disruptions to serving their customers^{Footnote 10} (Figure 21), employees using sick days for non-medical reasons^{Footnote 11} (Figure 22), employees complaining about others using sick days for non-medical reasons^{Footnote 12} (Figure 23), employees viewing the 10 days as an entitlement^{Footnote 13} (Figure 24), on the need to hire new employees to deal with absences^{Footnote 14} (Figure 25), extra work for employees to cover for absences^{Footnote 15} (Figure 26),  forecasting staffing needs^{Footnote 16} (Figure 27), and issues with completing essential tasks due to absences^{Footnote 17} (Figure 28). These comparisons were done using Chi-square test.

Interestingly, the majority of smaller organizations (1-19 employees) answered the following way:

• did not see a decrease in sick employees coming to work (did not see a decrease in employee presenteeism)
• did not experience disruptions serving their customers due to sick leaves
• did not perceive employees using these days for non-medical reasons
• employees did not complain about other employees using these days for non-medical reasons
• employees did not see these days as an entitlement
• did not need to hire new employees to cover for medical absences
• did not need extra work for their employees to cover for these absences
• do not struggle forecasting staffing needs
• do not struggle to complete essential tasks due to medical leaves

Next, the majority of medium organizations (20-99 employees):

• did see a decrease in sick employees coming to work
• did not perceive more employees using these days for non-medical reasons
• did not need to hire new employees to cover for medical absences.

Finally, the majority of large organizations (more than 100 employees):

• did experience disruptions serving their customers due to sick leaves
• did perceive employees using these days for non-medical reasons
• employees did complain about other employees using these days for non-medical reasons
• employees did see these days as an entitlement
• did need to hire new employees to cover for medical absences
• did need employees to do extra work to cover for these absences
• do struggle forecasting staffing needs
• do struggle with completing essential tasks due to medical leaves

Figure 20: text version

Belief that medical leave with pay has reduce the number of employees coming to work sick	Yes	No
Small	15	45
Medium	39	29
Large	25	27

Figure 21: text version

Belief that medical leave with pay has caused disruptions to services	Yes	No
Small	19	41
Medium	38	40
Large	36	24

Figure 22: text version

Belief that some employees use medical leave for non-medical reasons	Yes	No
Small	17	37
Medium	42	14
Large	41	14

Figure 23: text version

Belief that some employees complain about coworkers using this leave for non-medical reasons	Yes	No
Small	11	44
Medium	33	43
Large	40	20

Figure 24: text version

Belief that some employees see medical leave as an entitlement	Yes	No
Small	26	34
Medium	59	22
Large	64	6

Figure 25: text version

Belief that medical leave has led to hiring new employees	Yes	No
Small	7	55
Medium	14	66
Large	32	29

Figure 26: text version

Belief that medical leave with pay has caused extra work for employees covering absences	Yes	No
Small	24	38
Medium	46	28
Large	51	12

Figure 27: text version

Belief that medical leave has led to difficulty in forecasting staffing needs	Yes	No
Small	26	33
Medium	44	33
Large	50	17

Figure 28: text version

Belief that medical leave with pay has caused difficulties in completing essential tasks	Yes	No
Small	26	36
Medium	45	33
Large	52	16

Three tables in Appendix B (Table 4, 5, and 6) provide further details on each sector on the previous outcomes. It also provides disaggregated data on each sector based on size.

Qualitative Analysis

We conducted sentiment coding to assess attitudes and levels of satisfaction and participants' underlying responses. Each response was reviewed and assigned a sentiment category: positive, neutral, or negative, based on the language used and the implied or explicit attitudes toward medical leave policies, absenteeism, and related management practices. As an example, we assigned positive sentiment to responses that reflected supportive, constructive, or empathetic approaches (e.g., "We offer support to our managers," "We provide flexible work options," or "We work to create a positive culture"). Neutral sentiment was used when the response was factual, procedural, or lacked clear distinction tone (e.g., "Attendance policy in place," "Revised absence management program," or "Tracking sick leave data"), and negative sentiment was assigned to responses that showed clear frustration, dissatisfaction, punitive attitudes, or lack of employer-employee trust (e.g., "10 days missed is poor performance," "Costs have been risen too much," or "We go to disciplinary if an absence isn't justified"). French responses were translated and analyzed in parallel to ensure consistency and inclusivity. In the following section, words or sentences in quotation marks have been taken directly from respondents, while findings without quotation marks have been summarized and/or paraphrased.

This approach allowed us to not only quantify the distribution of sentiment across the dataset, but also to better understand the attitudinal undercurrents that may influence organizational culture. In the following section, we attend to each qualitative question in turn and provide an aggregate analysis based on participant sentiment.

Q1. Has your organization implemented measures (other than attendance bonuses) to limit absenteeism?

The sentiment analysis of 50 qualitative responses revealed a predominantly neutral tone across organizations when describing their approaches to attendance and medical leave. Neutral responses (58%) typically reference policy infrastructure, such as attendance management programs, monitoring systems, or procedural enforcement, without expressing a positive or negative stance. Similarly, mixed responses (8%) combined policy enforcement with education or employee support, indicating a nuanced or dual-track approach to absenteeism balancing accountability with compassion.

Examples of neutral policy changes or other measures included:

• Negotiated frontloading the 10 annual days starting in January, instead of accrual, with the strategy for employees to use the days prior to their busy Q4 season at the end of the year
• Revising attendance management to create more structure for handling "innocent" and "culpable" absenteeism (respondents' language); in other words, employees who are perceived as utilizing their paid sick leave because they are unwell (innocent), versus those who use it otherwise (culpable absenteeism)
• New attendance review periods with specific criteria to meet
• Digital tracking and reporting systems to quickly identify trends in absenteeism
• Performance planning in place with yearly KPIs
• Asking for medical notes after 10 sick days for each absence, possible disciplinary follow-up
• Several responses indicated that they have no issue with attendance and absenteeism; they do not see employees taking advantage in any way

Positive responses (24%) highlight supportive workplace practices, including wellness programs, flexibility, employee recognition, and transparency about the costs and benefits related to sick leave. These entries reflect a more employee-centered tone and efforts to foster workplace engagement and trust. Those who used proactive measures for the change in sick leave policy included actions such as:

• "We work to provide a positive company culture with regular feedback between staff and managers. We are looking at adding attendance to our employee recognition program but it's not currently part of it."
• Distributing educational material about sick leave to raise awareness
• Manager training and support
• Wellness programs and EAP supports
• An attendance management program that deals with excessive absenteeism with accommodations for working at home and programming to promote wellbeing
• Paying employees cash for up to 6 unused sick days or vacation
• Several employers openly discussed the impact of absenteeism with employees and focused on building trust and reciprocal understanding on the effects on team members.
• Attendance bonuses are being considered
• Meal days, gifts, and thank you cards are used as positive measures to build morale

Negative sentiments (10%) reflect more punitive or cost-driven attitudes, with language indicating concerns about abuse, costs, or strict disciplinary measures. While less common, these responses reveal tensions between compliance with legislation and organizational expectations. Some examples of negative language included:

• "10 days missed in a calendar year is POOR PERFORMANCE and warrants discipline under the Attendance Management Policy. Gov't may require us to pay it but does not mean it is acceptable to miss time for unacceptable excuses."
• "With the abundance of sick days, additional Stat days implemented by the Govt, and several other leaves with/without pay available, it is near impossible to suggest to employees that their respective absentee rate is excessive, otherwise said employee can make a simple complaint to labor standards and they will rectify that digression in the aggrieved employees favor."
• High costs from absenteeism that employers can no longer afford
• Points systems that are connected to absenteeism dashboards, automated processes for sending employee data to managers for progressive discipline as it relates to their collective bargaining agreement.

This distribution suggests that while procedural compliance dominates organizational discourse, 25% of employers are navigating the intersection of policy and employee wellbeing in more proactive and strategic ways, while the minority (10%) view the use of the additional sick days as taking advantage of the system.

Q2. In your organization, have some employees demonstrated the view that 10 days of medical leave with pay is an entitlement to be used fully every year, regardless of medical necessity?

The majority of the 174 responses were neutral, with a wide variety of experiences on the 10 days of medical leave. About 20% of responses showed clear negative sentiment, which was the same as positive sentiment. The remaining responses (60%) were neutral, with no strong sentiment. Negatively coded responses included frustration with leave being used like vacation, perceived abuse of the system, and employee attitudes being bolstered by their unions. Positive responses were received at the same rate and indicated that employees typically use leave only when needed, and no misuse was observed. While several participants strongly took issue with the CLC amendments, other respondents regarded the questionnaire as one-sided, as only employers were asked to respond. One employer suggested that employees have not commented, leaving our interpretation to the employer's experience. While this is a limitation that will be taken up fully in the limitations section, it is important to note that some of the employers who responded are hesitant to provide information that could negatively skew the perception of employees.

Positive responses include answers that suggest employees only take the days as they need them. About 20% of the answers were coded as "positive" towards the legislative changes. Examples of this type of response included:

• One response noted a difference in generational attitudes about work; older employees were less apt to take any sick leave days, let alone use the additional ten days post December 2021
• While employees take sick leave only when needed, most prefer the days to be monetizable
• Most of the positive responses stated that they had not observed employees demonstrate the view that their sick leave is an entitlement

Similar to the positive responses, neutral responses (60%) either provided specific information about leave usage, stated that they did not know how to answer this question, or that employees use the days as needed.

• One respondent noted that since December 2022, their absences have increased by an average of 2% per year. This has had no impact on the organization, as they have scheduled more employees to ensure coverage
• Neutral responses stated that they did not have the necessary information to comment, or that they had not heard this perception of the sick leave from their employees
• Some employers responded that the days are understood to be used as the employees wished, whether that was like a vacation day or a non-medical leave, but they did not elaborate further with value judgement (e.g., this usage is "bad" or negative for the company)

Negative responses (20%) included commentary about unions and unionized staff as being an issue for taking the sick leave, about being little recourse for employers to take against the time used for non-medical reasons, and about the heightened cost to the employer. Specific examples are included below:

• "Since the Government mandated Sick pay, we have employees calling in sick and using whatever Sick pay available almost regularly. It is a huge cost to us as we did not prior have sick pay and employees came to work."
• "Employees see leave as a vested right and use it excessively. There was very little communication prior to the coming into force. People quickly seized the opportunity to extend their weekends etc... In addition, they can really use them because the employer has no rights. they must pay without saying anything. The employer can request a medical note only after 5 days. There are several flaws in these paid leaves: If the government wanted to protect employees and set up a social safety net, it should have taken the financial burden of its decision. In addition, even part-time employees can take advantage of the 10 sick days. Moreover, the government should have analyzed and gradually implement this measure. Implement a measure and then assess its relevance. Unfortunately, federally chartered employers are at a significant disadvantage from this measure."
• "A couple of employees have viewed it as a form of vacation time. "
• "As there is no medical proof required to support the medical leave less then 5 days they are treated primarily as paid vacation days"
• "Both employees and union representatives have used the phrase 'use it or lose it' with respect to the annual entitlement of paid medical leave under the Code. While note universal, there are many who espouse the view that these days should be used "no matter what."

Those who responded with negative sentiment, although fewer than neutral, elaborated on their answers to discuss the cost to the employer, the perceived negative role of the union as supporting employees using their paid medical days, and the complication that medical proof might not be necessary, therefore suggesting they have little recourse or power to deal with potential policy misuse.

Q3. Since December 2022, do employees sometimes use medical leave with pay for non-medical reasons in your organization?

The overwhelming majority of responses (91%) were neutral, consisting mostly of short statements such as "no," "don't know," or "not that I've seen." These responses suggest that either employees do not misuse paid sick days, employers trust their employees and believe that they take the days only as needed, or that since many do not require a sick note, they cannot comment as they do not have the requisite data. Many respondents did not provide further elaboration.

• Some employers suggested that mental health was a reason some employees used their paid sick days, either for their own mental health, or for supporting family members who need support for their mental health: "An employee used medical leave to accompany a family member with mental health issues to seek treatment."

Interestingly, while only 4 respondents out of 172 (0.02%) described mental health as a component in their answer: one employer described mental health as an acceptable reason for taking a sick day, as it is part of overall employee health, a second described it as an excuse to take sick days, while two respondents described the use as needed for supporting their family members when they have run out of vacation days.

There were few responses that could be coded as positive in this data set, possibly due to the wording of the question, which did not invite supportive responses. The only responses that could be considered "positive" or supportive of employees would be those who indicate that there are no issues with employees taking medical leave with pay, or that they trust that their employees only use the days when they need them.

Negative responses (9%), while fewer in number, were significantly more detailed and often expressed clear frustration with perceived misuse of paid medical leave. These responses included examples, such as:

• Employees threatening to book sick time when personal leave is denied
• Patterns indicating avoidance of the requirement to provide medical documentation for short-term absences
• "As stated before based on the usage patterns since the introduction of paid sick leave we know that the vast majority of sick leave is used for non-medical related time off. Abuse is rampant and the employer is denied the tools to actively manage this by the regulations."
• "Although it's very difficult to prove in most cases, the increase in the use of paid sick days has been so dramatic that it can only be explained at least partially by abuse and misuse. We have examples of employees admitting they are using paid medical leave days inappropriately, for example, to attend a golf tournament."

While the neutral and positive responses provided mixed evidence as to whether employees use their paid medical leave for non-medical reasons, those who were more critical spoke strongly about employee misuse and abuse of the CLC amendments.

Q4. Has the introduction of 10 days of medical leave with pay on December 1, 2022, caused your organization to struggle to complete essential tasks more often? Note that the following question provides space for details.

Like other questions, there were mixed responses. Of 174 responses, 67 participants (39%) noted no issues with completing essential tasks, that they did not have the specific data, or that they could not comment as it was not a concern. Out of the remaining responses (61%), most noted that they have had issues with completing essential tasks to varying degrees, from needing to reschedule employees in the morning to the additional days making business operations difficult to maintain due to employee absences.

There were only a few positive responses, which spoke to the small size of the company as being a positive aspect, that all employees worked together as a team and realized that leave effects everyone. Another response suggested that "employee pride" was an aspect of their work culture that ensured essential tasks were covered:

• "We have been lucky enough to have employees take pride in their job and make sure it is either done or have someone else cover the actual necessities while they are off."

Neutral sentiment varied, with many simply stating that they have had issues with essential tasks, without providing further detail. The example below demonstrates that in terms of completing essential tasks, the paid sick days did not significantly change their productivity and did not change how much time employees took off from work. The change would have necessitated the unpaid days, however, to become paid after December 2022:

• "We did not have paid medical leave prior to the new rules, so employees that needed to take off for medical reasons did so without pay. The introduction of the paid medical leave did not increase nor decrease the amount of time people took off, so there was not any significant difference in the effect on the productivity"

Negative responses highlighted specific concerns, such as holiday staffing pressure due to clustering of sick days at the end of the year, the need to overstaff to compensate for anticipated absenteeism, and fiscal constraints due to paying out sick leave time if it was unused. To note, employers are not mandated to pay for unused paid sick days, but some organizations have strategically started paying employees to curb absenteeism. The selections below provide nuance into the effects on various employers:

• "The lack of policy clarity is translating to additional sick leave days and in turn, more unexpected and exorbitant costs. [Company name] has seen a 255% increase in the number of sick days used in 2023 compared to 2022. The stacking of paid leave days has resulted in nearly $10M in annualized cost for [Company name]. There are financial costs related to having additional headcount to cover the same essential tasks. There are Benefit costs due to overstaffing in order address an increase paid sick leave days. When employees call in sick, this increases the likelihood of overtime for employees that are working, to cover the same essential tasks and meet productivity targets. Unplanned sick day occurrences put stress on employees and impacts workplace morale as they would have to cover for their peers that have called in sick. There is productivity loss associated to increased paid sick leave days - it takes longer to complete the same essential tasks and meet productivity targets."
• "As mentioned before, because it renews on the Calendar year, we often struggle to keep up around the Christmas Holidays. We also over-staff before and after long weekends to try and make sure we are covered."
• "The number of sick days has crippled our operations. Enormous labour costs, coupled with low productivity, coupled with carbon tax, coupled with a free-for-all largely unregulated trucking industry with zero enforcement for NSC regulations, and now add tariffs, has created a perfect storm that will wind up in Canadas trucking industry heading for near collapse. We are not immune to this, and the government has yet to recognize there is a serious problem in our supply chain"

Those who submitted comments that were coded as negative were critical of the changes for various reasons related to completing essential tasks: labour cost increases for finding and replacing absent employees, low productivity, lower workplace morale, and issues with sick leave stacking that has had financial costs for larger organizations.

Q5. Has the introduction of 10 days of medical leave with pay on December 1, 2022, led to greater difficulty in forecasting staffing needs? Challenges could include understaffing due to unexpected absences or overstaffing to plan for potential unexpected absences.

The majority of the 111 responses were neutral, reflecting factual descriptions of scheduling, backup staffing, or seasonal trends without clear approval or frustration. Many organizations acknowledged needing additional staff during high-absence periods but did not characterize this as a significant disruption. A few negative responses indicated substantial difficulty forecasting for essential coverage, particularly in the context of 24/7 operations. Concerns included higher overtime, lower productivity, understaffing, and insufficient backup coverage.

Positive responses (10%) included supportive comments about workplace culture, communication around taking leave, and clear expectations. One example suggests that a certain level of absence has been expected, therefore accounted for during seasons of increased work or increased time of regular absence:

• "No, we keep communication open so that there are no surprises."
• "Employees give sufficient notice for medical days off."
• "No. Expected absence based on seasonal impact is accounted for."

Neutral responses included answers that ranged from "I don't know" and single-word responses such as "yes" and "understaffed," to nuanced responses about forecasting and strategically anticipating absences provided in the examples below:

• "Given the amount of medical leave used since December 2022, workforce planning has been adjusted to include medical leave replacements. Various departments may need to or have already increased staffing levels to cover the 10 days of medical absences."
• "We need to schedule an additional 2% employee to do the same amount of work - Snow storms, last 2 weeks of December were trends where we experience up to 25% -30% absenteeism rates that were not anticipated and impacted customer service and costs."
• "As a charter bus company, we can't overstaff drivers. It is 1 diver per bus. We have to deal with last minute replacements."
• "The trucking industry presents unique challenges that can impact customer relations. For example, when a driver becomes ill, it can disrupt the entire supply chain. However, by implementing effective contingency plans and fostering a supportive work environment, we can mitigate these issues and ensure smooth operations even in difficult situations."

Negative responses focused on specific difficulties with forecasting. The two examples below provide context for a 24/7/365 business operation that has faced difficulties finding enough staff and with paying higher overtime rates. For the longshore sector, staffing is more complex as labour is ordered three times per day, which makes forecasting more difficult to predict:

• "Ours is a continuous operation (24/7/365). This change has made it virtually impossible to staff adequately for long weekends and peak vacation season. While the likelihood of increased absences is predictable on holidays, junior employees can be forced to work and overtime can be called, there is often simply not enough people available to backfill these absences, and even mandatory overtime is sometimes refused. Overtime costs have increased, and productivity has dropped. Many jobs in our workplace are done in teams of two, meaning if one calls in sick and cannot be backfilled, the other employee is also unproductive for that shift."
• "As stated previously, employees have great flexibility when it comes to determining when they want to come to work in the longshoring industry. This has always made forecasting labour difficult as labour is ordered 3 times a day. We have no way of knowing how many people will show up on any given day. Sick leave has made this problem even worse. Employees who have confirmed orders can later call in sick and receive the same pay. Some days we have very few sick claims other days we are flooded with them. With no way to manage sick leave there is also no way to forecast it or our staffing needs."

Q6. Since the introduction of 10 days of medical leave with pay on December 1, 2022, has there been an increase in extra work for employees covering absent coworkers?

Most responses were neutral, suggesting that organizations either did not experience a significant impact or could not directly attribute an increase in extra work to the leave policy. The responses for this question were often brief, one-word answers, and did not provide elaboration. For example, out of the 168 responses, 60 (35%) fell into this category. Other answers simply stated "yes" or, "yes, it has led to more work."

Positive responses were similar to the previous questions, where employers restated that their employees do not abuse medical pay, or that they have not experienced an increase in work to cover absent coworkers. Neutral responses included those who "did not know" or retorts such as, "there is always more work for others when someone is off" or "longer days for other workers." One employer noted that absences do not simply add more work, workers who fill in for absent colleagues can "increase injuries in other workers" who need to work longer hours.

Negative responses revolved around workplace culture, "forcing" younger employees to work overtime shifts, overtime costs and employee fatigue:

• "People covering for people is a daily event now, and that has bred a very unhappy workplace."
• "For those who are really sick it's understandable, but for the others, colleagues simply don't want to replace them and we have to force the younger ones to work overtime."
• "Even after increasing the relief budget year-over-year since 2023, we are unable to meet operational requirements, thus we rely heavily on overtime (OT), which causes further fatigue amongst the employees."

Q7. In your organization, has the implementation of 10 days of medical leave with pay led to more employee complaints about coworkers using this leave for non-medical reasons?

Most responses were neutral and did not indicate awareness of employee complaints. Comments were typically brief or indicated no known issues. A smaller portion of responses showed signs of peer frustration, often tied to visible patterns of absenteeism or union-level concerns. Out of 103 responses, 43 (42%) said that it either was not a problem, they had not heard of employee complaints being an issue, or that they did not have enough information. Negative comments focused on employee morale, abuse of the system, and critiques of the amended legislation.

Neutral responses included replies such as one-word answers like "yes", or "somewhat" without further comment. The examples below convey that there is some discord between employees who take the time and those who do not. The second comment suggests that even if some workers are unhappy about its usage, they are not going to management to make a formal complaint about misuse.

• "Some are abusing the system and others don't like it."
• "There is always some speculation about leave, but no one has ratted anyone out for misuse"

Positive comments were few, with some one-word answers stating "no," "this is not an issue," or repeating that "employees don't abuse sick leave," except for the fulsome comment below:

• "Our workers do not use the leave for non-medical reasons and their coworkers are aware of when others are sick. There have been no such complaints."

Negative responses were more detailed and covered several thematic areas such as workload, the timing of taking paid sick days, and issues with workplace morale as one participant describes as "toxic." Further comments describe the policy as "designed for trouble and animosity" and that employers have no recourse, and some speculative complaints from "third parties" who have seen employees camping or hunting instead of being sick.

• "As employees need to take over the extra workload due to co-workers' medical leave. It's kind of obvious that some employees always take medical leave before and after their vacation."
• "This policy is designed to create trouble and animosity as not everyone is honest and if you claim medical leave there isn't much that can be done by an employer but sit back and watch someone cheat the system."
• "Yes, the toxicity due to this is huge. Morale is off the table."
• "It has led to complaints from the union leadership that we need to pay even out for 10 day sick in the hope they will come to work. The unions have an obligation to supply labour and are having a difficult doing so due to absenteeism. Given the widespread abuse of sick leave most employees, as our stats show, are all doing the same thing, trying to maximize pay for the least hours work."
• "Unplanned paid sick leave days impacts workplace morale and creates operational disruptions to our business. If/when employees take sick leave for purposes other than its intent, their coworkers need to unexpectedly cover the work. Employees want stability in their work and unplanned sick day occurrences is disruptive."
• "I have heard from third parties, complaints of workers that call in sick when their co-workers know that they have been seen "camping" or hunting."

Q8. Since the introduction of 10 days of medical leave with pay on December 1, 2022, have you seen fewer employees coming to work while sick?

Like the previous two questions, most responses were neutral, offering brief replies or mixed explanations without clear approval or criticism. Some respondents suggested employees are less likely to attend work while sick, while others expressed uncertainty or noted that patterns of presenteeism have not changed significantly. A few responses expressed skepticism that medical leave has reduced illness in the workplace, noting instead that the leave is used to extend vacations or weekends. No positive responses specifically highlighted reduced presenteeism as a clear benefit.

Positive comments continued to state that employees do not abuse their medical pay, and that misusing the days have not been a problem. A further positive comment stated that employees staying home when sick is a good thing since it "avoids contamination."

Many neutral comments were made about employees staying home or taking more sick leave since covid, and that not coming to work while sick is good for everyone. There were also one-word or short answers like "yes", "no," and "don't know." The below examples were interesting as only one respondent noted that a sick child could motivate an employee to stay at home, and the second was representative of many responses that stated employers do not want illness to come to the workplace.

• "Especially employees with young children - now less likely to come in to work sick."
• "Employees are encouraged to keep illness out of the workplace whenever possible."

Negative responses included value judgments about employees. One response considered a "good" worker as a good person because they go to work, and bad employees as "bad" people since they want to sit at home. Similarly, others suggest that since COVID-19, that employees either "do not want to work" and use the opportunity to stay home more often. One participant described the paid sick days as being used less for sickness and mostly for vacations or a longer weekend, and that illness in the workplace as not changing. Further, the last comment suggests that workers will use the paid days and place the "burden" of financial implications and staff shortages onto their employer.

• "Good employees come to work because they are good people. Bad employees call in sick, even when they are able to work, because they know they are getting paid to sit at home."
• "For an employee to miss work, it is because he was actually sick. Today, they use this leave whenever they have the opportunity."
• "Employees may still come to work sick, no more than previously. The 'Medical Days' are frankly used by employees to provide longer weekends, longer vacations, etc. but as they can be used for 'illness' without any ramification it is impossible to address this. When they're used for this purpose employees are incentivized to carry these medical days for other reasons that each employee deems important. Illness in the workplace has not changed in any meaningful way. "
• "Absolutely. Why would they come to work feeling sick if they know they will be paid? It takes the burden off them and places the burden on the employer - both financial and shortage of workers without notice."

More so than other qualitative questions, the question on employees going to work while sick revealed patterns of (some) employer value judgments and underlying attitudes towards sick leave in general.

Q9. Since the introduction of 10 days of medical leave with pay on December 1, 2022, has your organization experienced disruptions serving customers, clients, or supply chain partners due to increased employee absences from the use of medical leave with pay?

Nearly 40% of responses cited delays or service disruptions. These often referred to customer service impacts, supply chain delays, technician availability, or coordination breakdowns between transportation and logistics teams. Neutral responses were common and often stated "no," "n/a," or lacked elaboration. Positive responses indicated no operational issues, with 31% of responses stating that this was not an issue, since it could not be traced back to medical leave with pay, or that there has been no observable change since December 2022. Since most of the responses detailing disruptions provided sector-specific examples, the below excerpts demonstrate how service disruptions have occurred, and in some cases, what their impact has been on various business functions:

• "As a railway, we have experienced train delays and cancellations, which have in turn affected our supply chain partners and customers in the form of service delays, wait times, and cancelled services."
• "As answered in prior question(s) we have had drivers call in sick and had to hire out to outside delivery services, or in some cases resulting in rescheduling. Also, if our products (shipping Containers) need modifications or repairs, this may result in delays in getting these containers to our customers when we are understaffed due to medical leave."
• "Yes, as previously described we have to delay ships, reduce orders, send employees home while at the same time increasing their assessments to pay for the sick leave. The *** is funded by assessments from tonnage going through the Port of ***. We had to increase our assessment rates by approximately 50% and sick leave now accounts for almost half of our annual budget."
• "Yes. Because our delivery delays are felt throughout the supply chain. The impacts are numerous but difficult to quantify."
• "Delays in the logistics chain Ship must be unloaded or loaded again the next day since we did not have all the manpower to do the planned operations, impact on the train not leaving on time with the containers, impact on city trucks that cannot come to pick up the container at the scheduled time, Increased lead times for the store and the customer at the end of the supply chain. It also creates a lot of headaches and planning after planning, a lot of coordination with all these players, frustrations of deadlines and increased costs."
• "It's a minority for sure, but some staff will decide not to come to work, citing illness, knowing they will get paid. This causes crews to be short-handed, dispatch plans to have to [be] rearranged and both of these factors directly affect our ability to provide the level of service our customers expect. Service schedules may be delayed. Smaller crews result in longer job durations. Crew structure may be affected resulting in less efficient service delivery. The queue gets disrupted."
• "Due to an increase in absenteeism in our organization, we have seen delays in day-to-day operations. More specifically, on-time performance, baggage delivery, customer service, time to handle customer claims, and minimum turnaround times have been impacted. Overall, performance has been negatively impacted due to the high rate of sick calls when compared to before the CLC changes."
• "Increased delivery times, product shortages."
• "The workforce has become largely unreliable. And employers' hands are effectively tied because absences cannot be questioned in today's world."

Q10. Has the introduction of 10 days of medical leave with pay on December 1, 2022, impacted any other aspects of your organization, including its services or products? Please note the aspect and the impact.

While most responses were neutral, a significant portion (35%) of respondents explicitly described impacts on services, products, or internal operations due to increased absenteeism. These included delivery delays, reduced productivity, and added costs related to temporary staffing. A small number of negative responses reflected frustration or dissatisfaction with the operational impacts. Other responses described the financial strain due to overuse of the paid sick days, and one participant commented on the effects on collective bargaining. No positive responses were recorded regarding the effect on services or products.

Example Responses Indicating Service/Product Impact:

• "Historically, there's been a major impact on [service disruption business] metric since increase in number of sick days per day … There is a trend/correlation between the number of Sick days and the service Metric of Sickdays …All metrics are affected by a surge in sickdays 1. Same Day Business (% of business customers where repair service was available in 24 hours), 2. Same day next day res (% of Res customers where repair service was available in 48 hours), 3. Arrived late (Technician arrived in wrong interval), 4. PL (No technician presented to job) - Absence trends are usually forecasted depending on trend, but a surge will cause a disruption (No additional workforce plan will have an impact on DueDate services)."
• "As noted in prior questions, we have had to hire outside trucking companies to complete deliveries, we have hired extra yard man to ensure that we have staff on to make sure that our deliveries are ready to go out to our customers "
• "Beyond absenteeism Here are the many impacts - financial impacts, Increase in operating costs, Delay in deliveries to our customers, Customer dissatisfaction, Loss of productivity, Increase in marginal profits"
• "Being a trucking company some try to use the days when they are not scheduled to work, we had to set up procedures to cover that. We have increased pricing in some areas to offset the cost."
• "Financially with 10 paid stat holidays and 10 days paid sick days we are paying out of pocket 1 full month of wages which is not possible to continue in this current market."
• "Labour relations: Code sick days have been central topics during collective bargaining with all of our Canadian unions these last 2 years. The issue of "stacking" and the intersection of Code sick days with other negotiated leaves and short term disability programs, were all highly disputed and required significant trade offs to resolve. Arbitration decisions have resulted in conflicting guidance and negotiated solutions such as pay outs and premiums for not using sick days have not produced the desired results. Employee satisfaction / work environment: The disputes at the bargaining table also manifested in the workplace, particularly through conflict and friction between employees and their immediate supervisors. Regulatory: the timing of the introduction of Code sick leave with the updated Duty and Rest Period Rules for Railway Operating Employees, which came in to affect in the same time period, created a perfect storm of negative impacts on employee availability with respect to train crews, specifically."
• "Our biggest challenge is the permanent, part time people using 85% of the sick pay. If they are part time, their sick pay needs to reflect this. It's not fair for a part time worker to be paid the same as a full-time worker. At least divide their pay by the previous 20 days so they receive a portion as they are part time. We have literally had to go back 8 months to give a part time person "full time" pay, and this makes no sense and is not fair to any full-time person."
• "Impact on services Impact on recruitment activities Additional workload for management and HR in the management of absenteeism."
• "It had an impact where seasonal workers are prevalent (summer students). Summer students are hired for 4 months during the summer and therefore are entitled to 4 paid sick leave days. The vast majority use all 4 paid days before ending their summer employment contract. Given that summer students are hired to address a peak in operational requirements, this has, at times, impacted service delivery."
• "It has allowed people to not care about the company and its survival. We cannot afford this whatsoever. Companies under 20 need to be exempt from this. Any medical leave should be unemployment."

To note, for Q10, fewer participants answered (N = 106) than in the previous qualitative questions (N~175). Of the 106 responses, 31 (29%) commented that they had not experienced any operational issues since the introduction of the paid sick leave amendments. The remaining 75 responses were either brief, such as "yes, financial," or extensive, as seen in the above examples. Many participants, however, choose to not answer the last question.

Limitations

This research was subject to several limitations that should be considered when interpreting the findings:

• Sampling error - Because there were only up to 275 people answer each question, the results might not be as precise as if there were more responses.^{Footnote 21}
• Selection bias - Organizations with strong opinions or notable impacts may have been more likely to respond, potentially skewing the results.
• Self-reported data - the survey relied on self-reported data from employers without independent verification, raising the possibility of recall bias or subjective interpretation, particularly for qualitative submissions.
• Differentiated findings - differences in organizational size, sector representation, and unionization may affect generalizability. SMEs and underrepresented sectors may face distinct challenges not fully captured by the survey, and while larger organizations have shown in both quantitative and qualitative results that they have been more negatively affected by the introduction of the 10-day paid medical leave. Other organizations have used the opportunity to educate their staff and build morale through innovative human resource and interpersonal development approaches. The variation in experience should be considered when understanding the effects across sectors and organizational size.
• Long-term data needed - the short time frame between the implementation of the medical leave policy (December 2022) and the survey (March 2025) may not allow for long-term attitudinal, behavioural, or systemic impacts to fully emerge, as we learned in the qualitative results that many organizations have learned how to properly forecast leave, build employee morale, and have introduced positive reinforcements for only taking leave when it is required.
• Perspectives missing - the absence of employee (and stakeholder) perspectives means that this report reflects only the employer viewpoint, leaving employee experiences, compliance behaviours, potential issues with employee-employer relations, and deeper attitudes and motivations left unexplored.

Conclusion

The introduction of 10 days of paid medical leave under Part III of the CLC has reshaped leave management practices for some organizations across federally regulated sectors. This study found that while many employers have implemented new policies and tracking systems to accommodate the legislation, a significant proportion report operational difficulties and workplace culture shifts in how leave is perceived and used. Larger organizations and those in the transportation, logistics, warehousing, and communications sectors reported the greatest challenges, particularly in planning around peak demand periods and managing staff morale amidst increased absenteeism.

Quantitative data showed a clear increase in sick leave usage following the legislative change, with a notable rise in the full utilization of leave entitlements. To note, some of the increased reporting is due to employees previously not having any sick leave, to suddenly gaining 10 paid sick leave days post-December 2022. Employers expressed concern that the inability to request documentation for absences under five days limited their ability to verify need or discourage perceived misuse. The qualitative responses added depth to these concerns, highlighting perceptions of entitlement, fairness, and erosion of workplace norms in some settings, while other organizations have managed to implement positive reinforcements for appropriate use. Despite this, some organizations reported minimal disruption or even improvements in workplace wellness and clarity in policy expectations.

It is important to see how paid medical days impact actual productivity. Being able to take these days might lead to faster healing and higher levels of productivity upon their return, instead of a sick employee working for more days while being less productive. Further examining the impact of attendance bonuses or asking for medical notes, may help organizations to promote to employee wellbeing of their employees.

Overall, the implementation of paid medical leave appears to have had uneven effects, shaped by organizational capacity, collective agreements, attitudes toward leave and employee relations in general, and sectoral dynamics. Employers are generally complying with the provisions, but the friction with strained operational realities remains unresolved and differs greatly across employer experiences. This tension suggests a need for continued monitoring of outcomes as employer practices evolve.

Further research is warranted in several areas. First, gathering employee perspectives would provide a more complete understanding of how the leave is being used and perceived in practice. Second, comparative analysis between federally and provincially regulated organizations could contextualize the unique challenges of federal policy. Third, longitudinal studies tracking operational, financial, and cultural impacts over a longer period would yield insights into policy sustainability. Further, examining how collective agreements interact with legislative leave entitlements may help identify models of best practice for implementation and oversight. Lastly, deeply understanding employer needs across sectors and organizational sizes could offer options for differentiated policy implementation that is specific to the number of employees, seasonal operations, or other industry nuances that could be accounted for.

Appendix A - Questionnaire

ESDC Federal Jurisdiction Employer Survey on Medical Leave with Pay (Paid Sick Leave)

Appendix B - Data Tables by Organization Size and Sector

The following notes apply to Tables 4, 5, and 6:

Note 1. All but at most four businesses in road transportation are trucking businesses; hence, as per the presentation of the results in the main body of this report, the two sectors can be merged. For more on this matter, see footnote 3 on page 14.

Note 2. The outcomes are as follows: disruptions to serving customers, clients, or supply chain partners due to increased employee absences from the use of medical leave with pay; reduce the number of employees coming to work sick; increase in hiring new employees to cover for unexpected absences; more employee complaints about coworkers using this leave for non-medical reasons; increase in extra work for employees covering absent coworkers; difficulty in forecasting staffing needs such as understaffing due to unexpected absences or overstaffing to plan for potential unexpected absences; difficulties in completing essential tasks more often; employees using medical leave with pay for non-medical reasons; employees viewing the 10 days of medical leave with pay as an entitlement to be used fully every year, regardless of medical necessity.