Backgrounder: Pay Equity Consultations – What We Heard Report


The report summarizes feedback from 40 stakeholders, including employee and employer representatives and organizations interested in proactive pay equity in federally regulated workplaces. Their comments are grouped into four general themes important in informing the development of the new federal legislation.

Theme # 1: Coverage of New Pay Equity Legislation

  • For the most part, employee and employer representatives considered Quebec and Ontario’s practice of exempting workplaces with fewer than 10 employees acceptable.
  • However, employer representatives said students, casual employees, temporary workers and senior management should be exempted from the legislation, while employee and advocacy groups believed that the new legislation should be as inclusive as possible.
  • Stakeholders also generally felt that proactive pay equity should apply to firms participating in the Federal Contractors Program.

Theme # 2: Implementing Pay Equity in the Workplace

  • Both employee representatives and advocacy groups said that the concept of an establishment should be based on all of the operations of an employer, and that the scope of comparisons should be as wide as possible, meaning that one pay equity plan per employer would be appropriate in most cases.
  • Employer representatives, for their part, said that the legislation should provide flexibility and discretion for them to define their establishments, and that it should allow for multiple pay equity plans under one employer.

Theme # 3: Maintaining Pay Equity and Reporting Requirements

  • Employer representatives said that reporting requirements would be sufficient to identify any issues that needed to be addressed to maintain pay equity in the workplace. From their perspective, maintenance could also be tied to changed circumstances in the organization (e.g. a new job class or a major restructuring). They also generally favoured simple reporting in the form of a checklist every two to five years, as they felt annual reporting would be too onerous.
  • Advocacy groups agreed that maintenance reviews should be tied to changed circumstances but felt they should take place at least every two to three years, whichever comes first.
  • Employee representatives were in favour of regular, ongoing maintenance activities.

Theme # 4: Roles and Responsibilities

  • Employee and advocacy stakeholders said that the new legislation should require representatives of unionized and non-unionized employees to be involved in developing a pay equity plan as well as in the maintenance process.
  • Employer representatives, on the other hand, generally believed that employees should be engaged in the process in an advisory capacity rather than a decision-making capacity.


  • Stakeholders broadly supported the principle of pay equity—equal pay for work of equal value. There was also general agreement that the new legislation should have well-articulated requirements, clear definitions and an oversight body to provide guidance and support to workplace parties.
  • When it came to some specific elements of a proactive pay equity system, however, views from employer and employee stakeholders often differed, with employer representatives in particular expressing the need for flexibility, and favoured improving the existing system as opposed to replacing it.  Advocacy groups, for their part, focused on pay equity as a human right and women’s rights issue and favoured an approach that would take into consideration the fact that some groups are more disadvantaged than others.

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