Pay equity in Quebec: deadlines, maintenance and fines explained

When do you need to take action on pay equity

In Quebec, employers covered by the Pay Equity Act must complete an initial exercise and then assess pay equity maintenance every five years. The exact deadline depends on their history. A delay may require corrective action and expose the employer to penalties; fines under section 115 vary according to factors including the size of the enterprise.

An updated job description helps document the work. It does not replace the initial exercise, maintenance assessment or applicable postings and declarations.

Initial exercise maintenance or training what do you need

Not sure which applies to you? Our pay equity support can begin by clarifying your file and the next steps.

Pay equity maintenance deadlines are approaching in 2026 and 2027

Pay equity deadlines follow each employer’s own schedule. For employers whose previous maintenance obligation was due in 2021 or 2022, the next deadline normally falls in 2026 or 2027, on their anniversary date.

There is no single deadline for everyone. Completing work late does not automatically restart the cycle on the date you finally finished it. Retrieve your postings and check the date that should have been met.

Consult CNESST’s guidance for determining your maintenance date - French resource

Need help completing your pay equity maintenance assessment

You have your previous results, but jobs, salaries or the organization have changed? We can help reconstruct events, prepare the data and complete the agreed work, or support your team with the steps it wants to handle internally.

What fines apply to pay equity violations

Failure to meet certain obligations can lead to penal proceedings. Section 115 sets out the following ranges for employers, according to the size of their enterprise:

The prescribed amounts are doubled for a repeat offence. These penalties are not an automatic invoice issued as soon as a deadline passes: they are part of the applicable offence and prosecution framework. Read section 115 as presented by CNESST - French resource.

The consequences may extend beyond a fine. Depending on the circumstances, corrective work, salary adjustments, lump sums and interest may be due. Calculation and payment rules differ according to the type of work and the delay. CNESST also publishes a list of employers in violation. Understand CNESST obligations and verification - French resource.

Who must complete an initial pay equity exercise

The Pay Equity Act applies notably to employers whose enterprise reaches an annual average of 10 employees or more under the applicable rules. The workforce is not determined simply by counting the people present today: pay periods, exclusions and the employer’s history must be examined.

An employer already covered remains subject to the Act despite a decrease in employee numbers. For an employer newly covered under the current general rule, the initial exercise must be completed within the following four years; specific historical situations must be checked.

For example, an enterprise that became subject to the Act in 2022 under this general rule must normally complete its initial exercise by December 31, 2026. This example does not replace the calculation of your organization’s own deadline. Check your obligations with CNESST - French resource.

Need to complete your initial exercise but do not know where to start

You do not need to improvise a methodology or collect every piece of data before asking for help. We can clarify the work required, the information to gather and how to proceed.

Exact HR can complete the work set out in the engagement or guide you step by step. You retain the decisions and responsibilities that belong to you; applicable participation and committee requirements must be respected.

Why your job descriptions must reflect the work actually performed

Jobs sometimes evolve faster than their descriptions. Someone may now coordinate urgent requests, train new hires, handle sensitive information or serve clients with more complex needs. When these requirements remain invisible, the information used to evaluate the job may be incomplete.

Job class evaluation must consider qualifications, responsibilities, effort and working conditions. It concerns the requirements of the job, not the individual performance of the person holding it. See CNESST’s evaluation methodology guidance - French resource.

CNESST’s campaign launched on October 19, 2026 highlights less visible aspects of work in predominantly female jobs. Its campaign period is not a new legal deadline. Read about the campaign on the undervaluation of female jobs - French resource.

A change does not automatically create a pay equity gap. Its impact must be assessed. To prepare the information, you can also discuss a review of your HR services and documentation.

Does your team need pay equity training

Do your managers need to describe jobs? Do HR and payroll staff need to prepare data? Do the people participating in the work want to understand the criteria and steps?

Exact HR can train your team in pay equity and tailor the content to participants’ roles. Depending on the agreed need, training may cover:

• the distinction between the initial exercise, maintenance and declarations;
• documenting actual job requirements;
• evaluation factors and biases to avoid;
• events to track for maintenance;
• organizing data and responsibilities during the work.

Training helps your team contribute to the process. It does not replace the required work and postings. Its format, content and scope are clarified before the engagement.

How to prepare your work without starting from scratch

Here is a preparation process proposed by Exact HR, to adapt to your circumstances:

1. Retrieve the history. Gather available initial exercise and maintenance records, postings and declarations. Check the required dates, not just the dates on saved files.
2. Build a picture of the jobs. Identify job classes, descriptions and changes in responsibilities. Document the facts using a consistent method.
3. Gather compensation data. Prepare the rates, benefits and dated events needed for the period under review. The data required depends on the engagement and type of work.
4. Decide who does what. Determine the applicable participants and participation mechanisms, then the work assigned to Exact HR and the work handled internally.
5. Plan the remaining steps. Depending on the situation, the analysis must lead to corrections, postings, responses to observations and required declarations. Retain records under the applicable rules.

Complete project delivery or guidance choose the right approach

We can complete your work within the agreed engagement or work alongside you at each step. In every approach, the employer retains its obligations. Explore our pay equity support.