Implementing pay transparency requires thoughtful planning and assessment of current compensation programs, plans and policies.

On March 21, 2024, Ontario’s Working for Workers Four Act, 2024 (Bill 149) was passed into law by parliament. Under Bill 149, amendments to the Ontario Employment Standards Act, 2000 (the ESA) introduced new provisions requiring job postings to include expected pay or pay ranges, marking a significant milestone in workplace equity. Pay transparency is the practice of sharing compensation with candidates and employees in an effort to mitigate gender pay discrepancies and disparity. Currently, four jurisdictions in Canada (federal, British Columbia, Nova Scotia, and Prince Edward Island) have enacted pay transparency legislation. Ontario and Newfoundland and Labrador are poised to enact similar legislation signifying growing momentum across the country.

The legislation follows increasing demand from employees to have open and honest conversations in the context of base salary (pay) transparency in recent years. Organizations must therefore ensure they are prepared to handle any challenges or concerns that may arise.

The HRPA recently sat down with senior principals from Normandin Beaudry, who shared their insights and experiences from implementing pay transparency in organizations across Canada.

“Implementing pay transparency requires thoughtful planning and assessment of current compensation programs, plans and policies. Employers should take into account potential biases and perceived unfairness, including proactively managing risks related to pay gaps. Appropriate change management and effective communication are crucial factors in preparing employees and managers for rollout of pay transparency requirements, but employers should first consider the desired degree of transparency, ensuring it aligns with their organization’s values and goals,” said Darcy Clark, Senior Principal, Compensation at Normandin Beaudry

Diane White, Senior Principal, Compensation at Normandin Beaudry added: “It is important for employers to reflect upon what employees really want to know—most often, it is not who is being paid what, but rather what criteria are considered to determine and justify salary levels. Employers must also recognize that increased transparency may expose inequities with their pay policies and structures and may increase perceptions of inequity, leading to dissatisfaction, turnover and decreased performance. They should therefore invest in effective communications and prepare, educate, engage and equip leaders for discussions with their direct reports.” Organizations can also proactively encourage a more amenable workplace by providing a holistic overview of their total rewards, so employees better understand and appreciate all aspects of monetary and non-monetary rewards.

When employers review their pay programs, practices and policies Normandin Beaudry recommends that they ask themselves the following questions:

  • Are our salary structures current? Do we have market data to support this?
  • Are our pay practices and policies (i.e., merit, promotions) unconsciously gender biased?
  • Are our job levels, job evaluation practices and job descriptions up to date? When did we last conduct a pay equity analysis?
  • Do our managers and employees understand our total rewards philosophy?
  • To what degree do our leaders and employees understand the value of their total rewards?
  • How will we explain the inclusion of pay in our job postings to our employees?
  • How will we manage inquiries pertaining to the inclusion of pay information in competitors’ job postings?


Next Steps

Pay transparency holds promise in the journey towards fair and equitable compensation and program design, but its implementation demands thoughtful consideration and strategic planning. Companies must carefully maneuver between candidness and discretion, providing pertinent information to employees while managing the potential associated risks.

By enhancing total rewards programs prior to introducing new pay transparency policies, organizations can help their employees recognize the spectrum of monetary and non-monetary rewards.

Mr. Clark concluded: “Adapting to and embracing pay transparency are critical elements in ensuring that all employees are fairly compensated and help foster a work environment built on trust, mutual respect and inclusivity.”