Probe on Unpaid Work in the Airline Sector: Phase I - What we heard report

Minister's message

The Canada Labour Code (Code) provides protections for federally regulated workers, including an established minimum wage. It expressly prohibits unpaid work.

The Code explicitly requires that federally regulated employees must be paid an amount that is equal to, or greater than, the minimum wage.

The Government of Canada takes allegations about unpaid work seriously. Last summer, a key focus of the concerns raised by Air Canada flight attendants was that some of their work was unpaid. These allegations were deeply upsetting for many Canadians who understand that no one should work for free in Canada.

In August 2025, responding to these allegations, I launched a Probe on unpaid work in the airline sector, focusing on compensation practices for flight attendants. The Labour Program asked for written submissions and held a number of roundtables with industry and union representatives. The results provided a snapshot of the complexity of pay structures in the sector and pointed to experiences where some flight attendants feel they are undercompensated for work performed.

The data required for the department to fully analyze these claims was not easily accessed. In some cases, records were not available to compare pay with hours reported worked. This initial report, Probe on Unpaid Work in the Airline Sector: Phase I - What we heard report, does not identify a sector-wide failure to meet the Code's wage standard. However, the report identifies areas where compensation practices warrant closer examination. The findings underscore the need for further examination.

As a result, I have asked the Labour Program to conduct a deeper review, including asking the airline industry to undertake wage-compliance self-audits. This further examination will provide the details needed to assess the alignment of compensation structures with hours worked. The lack of records to compare with pay data means that these further investigations are necessary to complete this analysis. I have also directed the Labour Program to conduct inspections and investigations into known complaints. This work is already underway. Anytime the government identifies non-compliance with the Code, it will act to ensure federally regulated workers' rights are upheld.

I have also directed the Labour Program to determine how "work" is defined and applied under the Code in this sector. Key industry stakeholders will be engaged in the upcoming weeks to come to a shared understanding of wage protections, how they apply in practice, and the supports available to employees. This invitation is being extended to airline industry representatives and unions. In parallel, the Standing Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities is studying the issue and extent of unpaid work in this industry. The Government will carefully consider the Committee's findings, alongside stakeholder input, to determine whether policy changes are needed.

Canada can only be strong if we work together to protect fair and safe workplaces. This first report is a key component of ensuring that all federally regulated workers are compensated in compliance with the Code.

I thank all participants for sharing their experiences and perspectives and I urge cooperation in the next stage of the analysis.

The Honourable Patty Hajdu
Minister of Jobs and Families and Minister responsible for the Federal Economic Development Agency for Northern Ontario

Executive summary

The mandate of the Minister responsible for the Labour Program, the Honourable Patty Hajdu, Minister of Jobs and Families and Minister responsible for the Federal Economic Development Agency for Northern Ontario, is to promote safe, healthy, fair and inclusive work conditions and cooperative workplace relations in the federally regulated private sector, which includes the airline industry. Labour standards for airline workers, including those related to wages, are set out under Part III of the Canada Labour Code (Code). Although the Code provides unionized workplaces with the flexibility to negotiate pay structures to suit their unique operational needs, the role of the Minister is to ensure that these pay systems meet the standards established in the Code and to enforce those standards when they do not.

Based on allegations that the airline sector, specifically with regard to flight attendants, was not meeting pay standards established in the Code, on August 18, 2025, the Minister announced the launch of a fact-finding probe to examine these concerns. As part of the first phase of the probe, the Labour Program held four consultation sessions with 21 employer and employee organizations and received 14 written submissions. The purpose of these consultations was to hear from employers and employees in the airline industry about compensation practices, with a focus on whether flight attendants' pay complies with the requirements of the Code. This report summarizes the information and perspectives shared during these consultations.

There are approximately 20,000 flight attendants in Canada, most of whom are unionized. Larger carriers reported nearly universal union coverage, while some smaller carriers employ non-unionized staff. Compensation structures vary but are generally categorized into two models. The credit-based system,^{Footnote 1} which remains the industry standard in Canada and internationally, compensates flight attendants primarily for flight time (or "block hours"), supplemented by calculations called "minimum guarantees" and "duty or trip ratios" to account for non-flight duties. Entry-level block hour rates range from $26.42 to $40.38 and individual salaries vary depending on individual rates and calculations based on schedules and guarantees. One non-unionized employer uses a salaried model, offering predictable annual income of approximately $45,000 for entry-level positions. Both compensation models also provide a range of allowances and non-wage benefits, including in-flight meals, per diems and other employee benefits.

The Code provides flexibility for unions and employers to negotiate various compensation structures as part of collective bargaining, including systems that do not provide hour-for-hour pay. The credit-based compensation structure is an example of such a system. Over time, these structures have been jointly negotiated by employers and unions to suit the unique needs of the airline sector.

Introduction

The Canadian commercial aviation sector has undergone significant transformation since its first paying passenger flight in 1920. In the early decades of passenger flight, air travel was very expensive and relatively perilous. It was not uncommon to hire nurses as flight attendants to assist passengers medically. As air travel became less exclusive and safer, the number of flights and flight attendants increased dramatically and the nature of flight attendants' work and required qualifications changed.

Flight attendants in Canada formed the Canadian Airline Flight Attendant's Association in 1948, which subsequently became the Canadian Union of Public Employees' (CUPE) Airline Division. Currently, approximately 90 percent of flight attendants are unionized, for whom the terms and conditions of their work, including pay structure and renumeration rates, are negotiated between their unions and employers.

Flight attendants' pay structure often differs from that of traditional 9-to-5 jobs. While the "salaried model" for remuneration exists, the "credit-based model" has been the most common industry standard for decades, whereby calculations originated from counting and remunerating only the flight time (or "block hours") and has evolved to include other factors, such as minimum guarantees.^{Footnote 4} In recent years, at least partly due to rates of inflation outstripping wage growth, and increasing flight delays, flight attendants' compensation has become an increasing point of contention, with a focus on concerns regarding unpaid work for duties performed on the ground, outside of flight time.

On August 18, 2025, the Honourable Patty Hajdu, Minister of Jobs and Families and Minister responsible for the Federal Economic Development Agency for Northern Ontario, announced the launch of a fact-finding probe into compensation practices in the airline sector, with a focus on whether flight attendants' pay complies with the requirements of the Canada Labour Code (Code). This report summarizes the feedback received from employer and employee stakeholders throughout the consultation period.

Consultation process

As part of the first phase of the probe, the Labour Program held four virtual roundtables, two in each official language, on September 23 and 24, and October 2 and 3. These sessions were informed by a discussion guide, which included questions to which stakeholders were also encouraged to respond in writing.

In total, 18 employer organizations and three employee organizations from the airline sector attended the roundtables.^{Footnote 6} In addition, 14 stakeholders shared written submissions with the Labour Program. The consultations closed on October 17, 2025.

Please consult Annex A for a comprehensive list of participating organizations and Annex B for the list of discussion questions.

The key takeaways in the following section reflect the views of employer and employee representatives who participated in the virtual sessions and/or submitted written submissions. This section aims to provide a summary of the main points raised during this exercise and not to reflect every comment that was heard or received.

Workforce composition

There are approximately 20,000 flight attendants, including pursers and service directors, in Canada, most of whom are unionized. During consultations, employers reported staffing levels ranging from 25 to 10,500 flight attendants, reflecting significant variation across carriers. Among larger carriers, the only non-unionized employees are those in training or probationary periods. Some smaller carriers reported that their flight attendants are not unionized.

Compensation and benefits

Flight attendants' pay structure can be categorized into one of two models: credit-based or salaried. The credit-based model is the most common, particularly among employers with unionized flight attendants. This model originated from a period in time when flight attendants were remunerated only for flight time, or from the time an aircraft leaves the gate (block-out) to when it arrives at the gate (block-in). It evolved to the current day credit-based model, whereby flight attendants' remuneration is determined by the total number of "credits" that is calculated using various formulas, including flight time (or "block-to-block hours" or "block hours") and other factors, multiplied by an agreed pay rate (or "block hour rate"), determined through collective bargaining. In general, different duties result in different allocations of credits.

In addition, credit-based collective agreements provide for daily and/or monthly minimum guarantees, which establish a floor of credits (and therefore of wages) regardless of flight time. For example, most employers provide a minimum of 4 credits per shift (or "duty period"), regardless of the actual hours worked. Moreover, duty periods (i.e., a flight attendant's entire work shift) are factored into credit-based systems. Many airlines also explained that their use of "duty period guarantee" or "duty period ratio guarantee" means that flight attendants may receive about 1 credit for every 2 hours of work performed outside of block hours (e.g., boarding, delays, disembarking).

For multi‑day trips, including international routes, compensation may be calculated using a different formula. For example, "trip hour guarantee" or "trip ratio guarantee" may provide 1 credit per every 4 hours away from home base, for the total duration of their trip.

While the specific formulas vary by airline, a common feature across credit‑based models is that flight attendants are paid the greater of:

• their actual block hours
• 4 block hours
• the duty period guarantee
• the trip hour guarantee; or
• the minimum monthly guarantee

Stakeholders reported that entry-level block hour rates can range from $26.42/hour to $40.38/hour. Based on the Labour Program's estimates, full‑time entry‑level flight attendants under the credit-based system could earn between $23,423 and $38,020 per year^{Footnote 7}, though salaries are difficult to compare as monthly schedules and the minimum guarantees used by airlines can vary considerably.

Another compensation model, albeit less common in Canada, is the salaried model. This model is designed to provide predictable annual income while still recognizing overtime, specialized roles, and time away from base. This approach is typically applied to full‑time flight attendants working a standard 40‑hour week. According to an employer utilizing this model, an entry-level flight attendant makes approximately $45,000 annually,^{Footnote 8} with overtime compensated at time‑and‑a‑half. Under this model, all hours spent on duty, including pre- and post‑flight tasks, ground delays, and other required responsibilities, are counted toward weekly hours worked.

Some part‑time flight attendants in this structure are compensated on a per‑assignment basis, with reported examples including flat rates for standby or training periods, check‑in/front desk duties, and flight days.^{Footnote 9} Additional premiums may also apply, such as service director pay, allowances for extended time away from base, or premiums for specialized duties.

In addition to their block hour wages, it was indicated that flight attendants under both compensation models receive a range of allowances and non-wage benefits. For example, for multi-day trips, flight attendants are provided with in-flight meals as well as per diems for time away from home base. Some employers offer non-wage benefits including dry-cleaning allowances, paid parking, group insurance coverage and retirement savings programs including Registered Retirement Savings Plans and Deferred Profit-Sharing Plans.

Overall, both employer and employee stakeholders explained that while compensation formulas vary across employers, Canadian models are broadly aligned with international industry practices, including allowances and other non-wage benefits.

Both employer and employee stakeholders agreed that all duties of flight attendants, including loading and unloading planes, safety duties, training, etc., constitute hours of work that must be considered in the remuneration scheme.

Stakeholders, however, provided differing perspectives on whether flight attendants perform activities at the disposal of their employer that are not remunerated. Employee representatives emphasized that a significant portion of flight attendants' work remains unpaid. They noted that compensation is generally limited to block time, with no direct pay for pre‑flight preparations, safety checks, boarding, delays, or post‑flight duties, despite flight attendants being required to remain on duty, notably because of a delay. Where pre‑ and post‑flight work is compensated, employee representatives reported that it is often paid at a lower rate than the block hour rate and only recognized for a limited duration before departure and after landing. In many cases, compensation applies only when duties extend beyond the normal duty period, or when the duty period guarantee is greater than the actual hours flown. According to employee representatives, this structure leaves significant portions of regular duties either unpaid or underpaid.

Some employee submissions alleged that certain duties performed remain uncompensated including check‑ins, briefings, handling medical emergencies, assisting passengers with disabilities, and managing delays. Employee groups emphasized that ground delays are generally not compensated, except in specific circumstances where compensation is explicitly stipulated in the collective agreement.

All employers compensating their flight attendants with a credit-based remuneration system emphasized that the credit system and the block hour rate are designed to encompass the full scope of duties associated with flying, not only time in the air. They noted that ground activities such as boarding, safety demonstrations, passenger assistance, and post‑arrival responsibilities are incorporated into credit hours or covered through minimum guarantees. Employers noted that flight attendants' duty periods typically begin one hour prior to the scheduled departure time and conclude between 15 and 30 minutes after landing, ensuring that pre‑boarding and post‑arrival responsibilities are incorporated into compensated time. Some airlines provide additional compensation to flight attendants during ground delays, or when flight attendants are required to work beyond their scheduled duty periods.

Two airlines noted that compensation was not always provided in the traditional form. They explained that certain activities, such as online training or reserve periods without assignment, were not directly paid, but that flight attendants received some form of compensation through other unspecified mechanisms or allowances. Another employer indicated that all pre‑ and post‑flight duties are incorporated into weekly hours and remunerated at the flight attendant's block hour rate.

Concerns regarding unpaid work

Employers referred to subsection 168(1.1) of the Code, as interpreted through IPG-002, to argue that flight attendants are receiving at least the federal minimum wage over the course of their work shift, including time spent doing pre- and post-flight activities at the disposal of the employer. Most airlines interpret subsection 168(1.1) to mean that even if an employee is not paid the minimum wage for each hour of their work shift, their overall monthly earnings must average out to at least the minimum wage when divided by each hour of work for that month. Several airlines stated that they conduct regular wage reviews to ensure this remains the case.

At least one non-unionized airline, however, indicated that their part-time flight attendants who are paid per assignment rather than per hour do not always receive at least the minimum wage, especially when there are major delays or other operational issues. The Head of Compliance and Enforcement is conducting a follow-up inspection of this airline.

Employee groups indicated that monthly earnings for many flight attendants across certain airlines, particularly those earning only entry level pay rates, fall below the federal minimum wage (the greater of $17.75 per hour or the provincial/territorial minimum wage) when averaged out over each hour of work. Some unions claimed that whenever a flight attendant is subject to a block hour rate that is less than 2x the minimum wage, they are likely receiving less than the minimum wage given that, on average, block hours account for half of flight attendants' total duty periods (i.e., flight time over the time between reporting for and being released from duty). Unions indicated this to be the case for most major airlines, save for a few that provide base rates that are at least double the minimum wage, and provided various examples, such as:^{Footnote 10Footnote 11}

• at one airline, the union claimed that a flight attendant worked a 12-hour duty period but only received pay for 6 credit hours at a rate of $27.61 per hour, resulting in an average of $13.82 per hour for that period
• at a different airline, the union claimed that a flight attendant worked for 12 hours and 55 minutes and received pay for 4 credit hours and 57 minutes of block time, resulting in an average of $10.96 per hour for that period

Collective agreements and enforcement

Subsection 57(1) of the Code provides that all collective agreements must include a grievance and arbitration process to resolve disagreements. Subsection 168(1.1) requires that any disagreements related to minimum wage requirements (among certain others) must be settled through the collective agreement's grievance and arbitration process - provided that the collective agreement confers on employees, rights and benefits at least as favourable as the benefits conferred by the minimum wage provisions under Part III of the Code. The Labour Program consulted stakeholders to assess if unions have taken action to resolve concerns regarding unpaid and underpaid work, and if so, whether grievance arbitration was effective in resolving such disputes.

Most consulted airlines indicated that they did not have grievances regarding unpaid work. A larger airline noted that grievances had previously been filed respecting other allegations of labour standards non-compliance, including failing to pay the minimum wage and failure to properly compensate flight attendants performing occupational health and safety committee duties.

• In one such example, a union representing flight attendants brought forward a grievance that the airline was not paying the flight attendants at least the minimum wage. The arbitrator ruled in favour of the employer, stating that the overall compensation set out in the collective agreement conferred a greater right or benefit to the employee than they would have received under the minimum wage entitlements of the Code

Unions, however, offered a different opinion. They explained that the grievance and arbitration process provided for as part of collective agreements is not an ideal channel to address the issue of unpaid work.

• A union noted that they reached out to the Labour Program in May 2023 to seek clarification about what activities should be paid for flight attendants. The Labour Program reinforced that the Code requires that employees be paid no less than the minimum wage and that for unionized employees their collective agreement should establish their pay provisions and grievance framework. The union interpreted the response to mean that the issue is unlikely to be resolved through existing grievance and arbitration mechanisms and would require legislative or regulatory changes

Overall, unions representing flight attendants recommended that the Labour Program consider proactively investigating workplaces in the aviation industry and enforce Code requirements.

Clarity of labour standards

Most employer and employee stakeholders agreed that all ground duties, training, or time where flight attendants are at the disposal of their employer should be counted as hours of work. Collective bargaining and the resulting collective agreements are the appropriate vehicles to ensure that flight attendants are paid in a manner that respects the Code's standard.

In general, larger airlines indicated that they believe the Code's requirements and related guidance materials are clear and do not need to be revised. Some airlines whose employees are unionized regularly carry out reviews to ensure compliance with labour standards under Part III, in collaboration with the union.

Conversely, smaller, non-unionized airlines indicated that, while the Code's general requirements are clear, how they apply to work in the aviation industry, which often uses complex pay structures due to the unique nature of the work, is less clear. For example, one airline stated that they do not understand how working time requirements apply to on-call time, preparation periods (i.e., before a flight takes off), and time away from home base (e.g., on a layover).

One employee group said that requirements under the Code and its regulations are too vague and flexible. They expressed that the lack of a definition of "work," the reliance on grievance processes to resolve disputes, and subsection 168(1.1), which states that minimum wage requirements do not apply to employees covered under a collective agreement that provides rights and benefits at least as favourable as the benefits conferred by the minimum wage provisions under Part III, all perpetuate the issue of unpaid work among flight attendants. They argue that reliance on individual complaints is inadequate.

Stakeholder recommendations

Consulted unions recommended that the Government pursue policy changes to resolve this issue. These changes can be categorized as follows:

Conclusion

The Labour Program is committed to protecting workers, including flight attendants, and supporting productive and fair workplaces. The Labour Program is grateful to all the organizations that took the time to meaningfully engage, whether it was during the roundtable discussions or via a written submission.

Unionized employees who believe they are not being compensated a minimum wage are encouraged to file a grievance with their union, in accordance with their collective agreement. All employees (including unionized employees) who believe they are being paid less than the federal minimum wage may file a formal complaint with the Labour Program. The Labour Program will inspect formal complaints. Previously, complaints by unionized workers whose collective agreements provided a third-party resolution mechanism were referred to the union.

Key findings

Overall, the consultation and work to date have not demonstrated a sector-wide failure to compensate flight attendants in accordance with the Code's wage requirements.

• Airlines and unions agree that all flight attendant activities, including time spent in the air and on the ground, is work and should be remunerated as such
• Airlines and unions disagree on whether certain activities are adequately remunerated
• The initial findings of the probe suggest that the credit-based compensation structures commonly used by airlines are compliant with the Code. However, the information made available to the Labour Program during this consultation was not sufficiently detailed to ascertain whether these systems, when used by specific airlines, could result in isolated situations where flight attendants earn less than the minimum wage
  • Under the credit-based pay structure, flight attendants do not receive an hourly wage. Rather, they receive pay based on a credit system, which is intended to compensate both flight time and associated ground duties
  • This type of compensation structure is permissible under the Code if employees are receiving at least the minimum wage overall (e.g., if their pay is at least equal to the minimum wage when averaged out over a certain period)
• Unions provided evidence that suggests some entry-level flight attendants, in certain cases, might not receive at least the minimum wage if their pay is averaged out over each hour of their work shift. Given that the Code allows for unionized employees to be paid under alternative compensation structures, which could involve the averaging of hours over a longer period (such as a week or month), this information is not sufficient to determine whether minimum wage requirements are being violated
• There is widespread dissatisfaction among flight attendants regarding their pay. According to unions, wage rates have not kept up with inflation, nor have they increased in line with increases to the federal minimum wage. This has resulted in a pay structure that is less beneficial to flight attendants today than it was when the unions first agreed to it

Next steps

Although the consultation did not find evidence of a sector-wide problem, the specific case issues raised by the unions merit additional follow-up work to ensure the Code is being upheld.

The Labour Program's Head of Compliance and Enforcement will convene a special meeting in February 2026 of the Labour Standards Advisory Committee, with an expanded invitation to the airlines and associated unions, to review the Code's minimum wage requirements in detail, their application, and the recourse mechanisms available to employees if they are paid below the minimum wage. Members will also be invited to share their views on whether regulatory or legislative amendments are needed to further clarify the meaning of work.

To ensure compliance with the Code, the Labour Program will take additional steps:

• employers in the airline sector will be requested to conduct self-audits of their pay records to demonstrate that all flight attendants, including the junior ones, are paid in accordance with the Code and share the results with the Labour Program. If employers do not voluntarily comply, the Head of Compliance and Enforcement could issue an order to conduct the audits or even issue an administrative monetary penalty for failing to comply
• complaints made to the Labour Program that the Code's standard is not being met will also be investigated

If non-compliance is identified, the Government will take appropriate action to ensure the Code is upheld, including inspections, compliance orders and administrative monetary penalties.

These concrete next steps, along with the results of the Standing Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities (HUMA) study^{Footnote 14} on the impact of "work" not being defined under Part III of the Code, will help the Government determine whether any additional actions are needed, such as expanding the guidance for the airline industry on what constitutes work in the IPGs, or regulatory or legislative changes to clarify what constitutes work in federally regulated sectors, including airlines.

The Labour Program is available to receive further data from airlines and union representatives, such as detailed pay records for part-time and entry level flight attendants and any documentation regarding the flight schedules and associated delays.

Annex A: Consultation participants

Annex B: Discussion questions

1. How many flight attendants are employed in your workplace/by your employer? How many are pursers/service directors?
2. Are flight attendants (including pursers/service directors) unionized? Are there exceptions for certain employee categories?
3. Please describe the pay structure for flight attendants, including rates of pay (e.g., duty period guarantee credits and trip hour guarantee credits) and allowances (or other non-wage benefits).
4. Are there activities where flight attendants are at the disposal of the employer but are not remunerated?
   1. If so, what are the activities?
   2. Are employees compensated for such activities in other ways?
5. Are flight attendants paid at least the minimum wage for every hour they work, as per the meaning of work under IPG-002? If not, please elaborate.
6. If your workplace is unionized, has the collective agreement's grievance and arbitration process been used to resolve disagreements regarding unpaid work? If so, what was the nature of the grievance? What was the outcome?
7. In your view, are the requirements respecting hours of work and minimum wage requirements under Part III of the Code, and related interpretations in IPG-002, clear? Please explain.
8. Are there any changes (e.g., additional guidance; regulatory or legislative amendments) that would help clarify the hours of work or minimum wage requirements to which flight attendants are entitled?
9. Is there anything else you would like to bring to the Labour Program's attention regarding this issue?
10. Do you have any questions?

Annex C: Glossary of key terms

Credit‑based pay model:
Is the industry standard for flight attendant compensation. Pay is determined by credit hours, which generally reflect block time (the period from when an aircraft leaves a gate at its departure airport (block-out) until it arrives at the gate of the destination airport (block-in)) and certain ground duties. Each credit hour is multiplied by the negotiated rate, and airlines typically guarantee a minimum number of credit hours per month to ensure a baseline salary. The model is designed to encompass both in‑air and ground responsibilities.

Block-to-block:
Time refers to the period from when an aircraft's parking brakes are released, and it leaves the gate at its departing airport (block-out) up until the moment the aircraft comes to a complete stop at the gate of the destination airport and its parking brakes are set (block-in).

Block-hour rate:
Is the rate of pay for each hour of block-to-block flight time.

Minimum monthly guarantees:
Are the baseline number of credit hours airlines commit to paying flight attendants each month, regardless of actual hours flown. Typically ranging from 65 to 80 hours depending on the airline, these guarantees are designed to provide a stable income even when schedules are reduced, flights are cancelled, or operational changes limit flying time.

Duty period:
Refers to the span of time a flight attendant is considered on duty by the airline. It begins when the employee reports for work and ends when they are officially released after completing post‑flight responsibilities. A duty period encompasses all responsibilities performed both on the ground and in the air, including pre‑flight preparations, boarding, flight operations, layovers, and post‑flight duties. The length of pre- and post-flight periods is pre-established in collective agreements and may not necessarily reflect the actual time needed to complete those responsibilities on every flight.

Duty period guarantee:
Ensures flight attendants receive a minimum number of pay credits for each duty period, regardless of the actual flight time. This guarantee was established to protect flight attendants from earning disproportionately low pay on long duty days that involve fewer actual flight hours.

Trip hour guarantee:
Ensures flight attendants receive a minimum number of pay credits for an entire trip or sequence of duty periods away from home base, regardless of the actual block hours. The guarantee sets a baseline number of credit hours per hour away from home base.

Home base:
Is the airport where flight attendants normally begin and end their scheduled duty periods.