ARTICLE
1 October 2025

Are You Ready For Pay Transparency?

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Osler, Hoskin & Harcourt LLP

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If you have 300-999 employees in British Columbia, you are required to prepare and post your first annual pay transparency report regarding gender pay gaps by November 1, 2025...
Canada Employment and HR

If you have 300-999 employees in British Columbia, you are required to prepare and post your first annual pay transparency report regarding gender pay gaps by November 1, 2025, pursuant to the B.C. Pay Transparency Act and Pay Transparency Regulation. Note that federally regulated employers are not subject to this B.C. legislation.

As outlined in our previous Osler Updates in June 2023: Trending towards transparency: British Columbia passes pay transparency legislation and November 2023: Update on B.C. pay transparency and Ontario announcement of new pay transparency rules, the B.C. government and six Crown corporations were required to post their first report by November 2023. Employers with 1,000 or more employees were required to post their first report in November 2024. Employers with 50-299 employees will be required to post their first report next year by November 1, 2026. As the legislation currently stands, employers with fewer than 50 employees will not be required to post a report.

The government of B.C. has developed an online Pay Transparency Report Tool (the Tool) to assist employers with the creation of the report. To use the Tool, employers will need a B.C.eID. Employers must collect the following employee information

  • Gender classification
  • Hours worked
  • Ordinary pay
  • Special salary
  • Overtime hours
  • Overtime pay
  • Bonus pay

Employers must make reasonable efforts to collect gender information from employees who must be notified that the information is being collected for the purpose of preparing a pay transparency report. Gender information must be self-identified and voluntarily provided by employees and, if an employee chooses not to provide it, the employee's data must still be included in the report with his or her gender marked as "unknown".

The B.C. Guidance for Preparing Pay Transparency Reports Using the Online Reporting Tool provides further information on collection and using the Tool.

Based on the data submitted to the B.C. government since it began mandating reports, the government has claimed to have seen improvement in the gender pay gap, specifically in the agriculture, forestry, fishing and hunting industries. See the B.C. Information Bulletin on this topic.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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