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Normandin Beaudry

Mandatory report on pay equity


There, in black and white

NB Bulletin Vol. 14 N. 4, April 2011

Section 4 of the Pay Equity Act requires that employers submit a report on implementation of the Act in their organizations. The Règlement concernant la déclaration de l'employeur en matière d'équité salariale, effective March 1, 2011, stipulates the content and form of the mandatory report on pay equity.

The report on pay equity is a short administrative document confirming pay equity measures taken. It must be filed annually.

Objectives of the report on pay equity

The report on pay equity is a concrete measure used by the Commission de l'équité salariale (pay equity board) to track progress in implementing pay equity by concerned employers. The reports may also be used to target the Commission's audit interventions with employers.

Who is required to produce a report on pay equity

Whether they are subject to the Pay Equity Act or not, employers who have declared six or more employees1 in their annual declaration to the Registraire des entreprises in the preceding year must file a report on pay equity starting this year. As with the declaration to the Registraire, employers have six months after the end of their tax year to file the report on pay equity.

Employers whose fiscal year ends on April 30, 2011 will be the first to have to produce a report on pay equity. The Commission de l'équité salariale plans to send reminders to all employers. Letters will be sent in the last month of the fiscal year. However, employers are required to submit a report on pay equity even if they do not receive a reminder.

The obligation to submit a report belongs to the employer and not to a particular individual. However, the person who files the report on pay equity must have the employer's clicSÉQUR express access code.

How to produce a report on pay equity

Reports on pay equity may be completed on line with a variety of platforms, including Québec Portal and (French only). Though the Commission de l'équité salariale will be the keeper of the information provided in the report on pay equity, any questions employers have about the report will be answered by Services Québec.

Content of the report on pay equity

The report contains information identifying the employer, its legal obligations under the Pay Equity Act and its compliance status as of the report submission date. More specifically:

  • The company's jurisdiction, federal or provincial
  • The date the company started operations in Quebec
  • The number of employees, computed as specified in the Pay Equity Act2
  • The posting date of the results of the pay equity process or the pay equity audit, as applicable

Last, the report on pay equity is in itself a confirmation that its content is true and accurate.

An employer who fails to submit a report on pay equity or to provide accurate information contravenes the Pay Equity Act and, under section 115, is liable to be fined between $1,000 to $45,000, depending on the size of the company.


1 Not to be confused with the minimum of 10 employees for the Pay Equity Act to apply to an employer.
2 The number of employees is computed as set out in section 6 of the Pay Equity Act. Employees excluded are indicated in section 8.


Please feel free to contact us for additional information.

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