The Pay Equity Act, which came into force in 2021, requires that federal employers prepare a Pay Equity Plan by no later than September 3, 2024. A non-unionized employer with more than 100 employees or a unionized employer with over 10 employees was required to establish a pay equity committee to create the Pay Equity Plan.
The Act requires that employers post their draft Pay Equity Plans for employee comment at least 60 days in advance. During the 60 day period, the employees to whom the draft Pay Equity Plan applies are entitled to provide written comment on the draft. The comments are to be given to the pay equity committee or, if the threshold for creating a committee has not been established, to the employer.
In order to allow for this comment period, employers should take steps, if they have not already done so, to complete and post the draft Pay Equity Plan before July 2, 2024. Along with posting the draft Plan, federal employers must include a notice informing the impacted employees of their right to provide comments, and the timeframe and manner in which they may do so.
For more information regarding your obligations as a federal employer under the Pay Equity Act, please contact Ilan Burkes or Vincent Johnston.
