Human Resources Legislative Update

Update on Federal Pay Equity Plan Posting Extension Requests

Human Resources Legislative Update

Update on Federal Pay Equity Plan Posting Extension Requests

Date: May 28, 2024

As discussed in our March 11, 2024 Human Resources Legislative Update, federally regulated employers are required to post their final pay equity plans and notices of pay increases by September 3, 2024. An employer may file a request for authorization to extend this posting deadline, and guidance documents related to this authorization process are available through the Office of the Pay Equity Commissioner’s Pay Equity Portal (Portal).

An employer who makes an authorization request is required to complete the relevant form in the Portal and provide information about:

  • the efforts the employer has undertaken to post the pay equity plan (Plan) by the legislated deadline
  • why the employer is unable to meet the deadline
  • the proposed extended deadline for posting the Plan
  • information about each workplace party that may be affected by the authorization request
  • how the employer will complete any remaining work so as to get the Plan posted by the extended deadline
  • why an extension is appropriate in the circumstances and the potential impact if the extension is not granted

An employer who submits an authorization request is also required to notify employees through a “Memo to all Employees” document found in the Portal. As part of its request application, an employer must provide evidence to demonstrate it has complied with this requirement.

    For more information on how to request an extension of the federal pay equity plan posting deadline, please contact your regular Hicks Morley lawyer.


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