On December 6, 2018, Bill 57, Restoring Trust, Transparency and Accountability Act, 2018  (“Bill 57”), passed Third Reading and received Royal Assent. As a result of Bill 57, the Pay Transparency Act, 2018  (“Act”) will not come into force on January 1, 2019 as expected, and will be put on hold to allow the government to engage in public consultations.

As we wrote in our earlier post, Bill 57 does not change the substantive content of the Act, although it is foreseeable that future legislation will do so. The new government has quickly implemented many significant changes in labour and employment law. From this standpoint, it seems likely that the government will amend or even repeal the Act, as opposed to simply delaying the in force date.

Key Takeaways

For now, employers should minimize the time, money and resources spent on achieving compliance with the Act. Employers who have already implemented changes may find it more cost-effective to simply leave those changes in place until substantive legislative changes occur. On the other hand, employers who are still in the process of developing and implementing changes are likely better off putting their changes on hold until further notice.