2020 pay equity audit

It’s the fourth 5-year audit since the first pay equity plan in 2001. Since 2010, employers have been required to ensure, every five years, that pay equity is maintained. The 2025 audit will be conducted to determine whether events in the system, the organization or the enterprise since the 2020 audit have reintroduced pay gaps between predominantly female and predominantly male job classes, and to identify any measures needed to correct the situation.

For the first time since 2001, the Treasury Board and the seven major labour organizations covered by the parapublic plan have agreed that the 2025 audit will be conducted by a joint committee. The pay equity audit committee was established for this purpose, in compliance with the Pay Equity Act, in September 2025. 

The APTS has a seat on the committee along with the CSN, FTQ, CSQ, FIQ, SPGQ and FAE (together, these organizations make up the Intersyndicale). As a member of the joint committee, the APTS will make representations to ensure that all of the job titles it represents are fairly and consistently evaluated, and will participate in the evaluation of these job titles and all other job classes in the parapublic plan.

The parapublic plan is one of the pay equity plans for which the Treasury Board is responsible. The parapublic sector includes colleges (cegeps), school boards and school service centres, and health and social services institutions covered by the Act respecting the process of negotiation of the collective agreements in the public and parapublic sectors. 

The Act states that there will be only one pay equity plan for all employees represented by certified associations. 

In January 2026, before the audit committee began its work, the APTS surveyed all of its members to get a full picture of changes that might have had an impact on your job titles. 

There will also be a large-scale data collection effort conducted by the audit committee among all job classes included in the pay equity plan. Job evaluation questionnaires will be sent to subsets of employees holding these job titles; respondents will be selected to accurately reflect the characteristics of each job class, according to sampling criteria and rules adopted by the audit committee. 

During this process, respondents asked to fill out the job evaluation questionnaire will be in a position to identify any changes that may have modified the value of their job. 

The date of the first posting is not yet known. Once the audit committee has collected data, analyzed events, and determined whether or not there are discriminatory wage gaps, it will be obliged to post its findings. Details about the posting are yet to come.

Once a pay equity audit committee has been set up, employees and unions are no longer allowed to file complaints related to the compliance of pay equity work. That is possible only when the employer is alone in conducting the pay equity audit. This is a major change in relation to previous pay equity audits. 

Once the audit has been carried out, a complaint may be filed with the CNESST only if it can be demonstrated that the audit committee or the employer acted in bad faith or in an arbitrary or discriminatory manner, or in a manner that did not comply with their legal obligations.

When the audit is carried out by a joint committee and the two parties are unable to agree as to the application of the Act, one of the parties (such as the union party) can submit the dispute to the CNESST (Commission des normes, de l'équité, de la santé et de la sécurité du travail).

The APTS wanted to be involved in carrying out the audit before results were posted. Being part of the audit committee gives the APTS the power to play a decisional role with the Treasury Board throughout the various stages of the audit, such as identifying job classes and their predominances and determining the evaluation method.

Our direct participation allows us to adopt a proactive and transparent approach in compliance with the Pay Equity Act, and will help prevent multiple complaints to the CNESST that would make the process highly litigious.