# 2025-203 Pay and Benefits, Allowances and Benefits, Environmental Allowances, Specialist Pay

Case summary

F&R Date: 2026-05-12

The grievor contended that their Chief Warrant Officer (CWO) position within the Canadian Special Operations Forces Command (CANSOFCOM) should be entitled to pay under Compensation and Benefits Instructions for the Canadian Forces (CBI) 204.31 – Pay – Special Forces and Search and Rescue Specialists. The grievor argued that their position should be considered a peer to the CWO positions eligible for pay under CBI 204.31. 

The Initial Authority (IA) denied redress, stating that CBI 204.31(1)(e) stipulated that only CWO employed directly within a Special Operations Forces (SOF) function are entitled to SOF pay. Four CWO positions were deemed to meet that requirement, but not the grievor's position. In reply to the IA, the grievor also argued that the position was employed in a SOF function.

The Committee noted that the IA misinterpreted CBI 204.31(1)(e) and clarified that it instead stipulates that Search and Rescue (SAR) CWO must be employed within a SAR function for entitlement, but that for SOF CWO they must instead occupy certain named positions, specifically the Command CWO and the Regimental Sergeants Major of CANSOFCOM units, to be entitled to pay under CBI 204.31. The Committee recognized that while there was some flexibility for SAR CWO positions to be deemed eligible, there was no flexibility in the entitlement criteria for SOF CWO. Since the grievor did not occupy one of these positions, the Committee found that they held no entitlement to pay under CBI 204.31.

The Committee determined that the grievor did not substantiate that their position was a peer to the designated positions. The Committee concluded that the grievor had not demonstrated that it was unfair or unreasonable that the position in question was not included for entitlement under CBI 204.31 and found that the grievor was not aggrieved. 

The Committee recommended that the Final Authority not afford the grievor redress.