Hi Susie! Good question. The short answer is yes, employers subject to the relevant pay-transparency legislation do need to take certain steps, but there is no general blanket federal law in Canada that says “every employer must have a pay transparency policy.” The obligations depend on jurisdiction and employer size.
What pay-transparency laws currently require
In the Pay Transparency Act (BC-specific), which came into effect May 11, 2023, employers must include the expected pay or pay-range in all public job postings.
This law also prohibits employers from asking job applicants about their past salary history (with limited exceptions) and protects employees who ask about or disclose pay from reprisals. It requires larger employers to prepare and submit annual pay‐transparency reports (e.g., gender-pay gap info) and make the report available to employees.
In the Working for Workers Four Act, effective Jan 1, 2026, employers with 25+ employees who post publicly advertised jobs must include “expected compensation or range” in the posting, among other rules (such as disclosing AI use in recruitment).
The federal level (for federally-regulated employers) has a related framework under the Pay Equity Act which mandates proactive pay‐equity plans, but it does not generally require posting salary ranges in all job ads across all employers in Canada.
Does the law require a specific “policy” document?
While the legislation requires certain actions (posting pay ranges, banning salary-history questions, reporting, etc.), it does not always explicitly require a standalone “pay transparency policy” document in all jurisdictions. The requirement is more about compliance with the substance of the law (job postings, disclosures, protections) than about creating a standalone policy heading “Pay Transparency Policy.”
That said, from a good-governance and risk-mitigation perspective, having a written internal policy (or procedure) is strongly advisable. It helps ensure consistent treatment, provides clarity for managers, and evidences proactive compliance.
I hope this helps! You can refer to our Pay Transparency Template if you want to implement one at your workplace or update your current policy.
-HRInsider Staff
