BC Pay Transparency Act – mandatory reporting drops from 300 employees to 50 in 2026

British Columbia’s Pay Transparency Act, SBC 2023, c 17, [the “Act”] was passed on May 11, 2023. The Act intends to reduce barriers and promote fairness in the workplace. An integral part of the legislation is the requirement that certain employers must prepare and publish annual pay transparency reports.  

Who are the employers? 

The Act qualifies two ways to be a “reporting employer”. First, the Act lists several government bodies or related corporations, such as British Columbia Transit and British Columbia Hydro and Power Authority, which are deemed upon assent to be reporting employers. Second, there is a phasing-in provision that deems employers as reporting employers depending on how many employees they have.  

In 2024, the first year of the legislation, only employers with 1,000 or more employees were required to report. In 2025, employers with 300 or more employees were required to report. In 2026, employers with 50 or more employees will be required to report. The decrease from 300 employees to 50 employees represents a significant jump and many employers in British Columbia are now required to prepare and publish pay transparency reports.  

What must the reports contain? 

The reports must be published by November 1 each year and be made publicly available on either the company’s website or if the company does not have a website, then in a conspicuous place in each workplace. The report, generally, must disclose information about gender-based pay differences at the company. The Pay Transparency Regulation, BC Reg 225/2023, [the “Regulations”] provides a comprehensive overview of everything that must be included in a pay transparency report.  

Each report will have a “reference category” which is used to compare the mean and median rates of different metrics such as hourly rate, overtime pay, and bonus pay, between gender categories. For example, if you employ 10 or more people who identify as men then the reference category will be man.  

Examples of the information to be included in the pay transparency reports includes:  

1. the name of the reporting employer; 

2. the reporting employer’s mailing address; 

3. the dates on which the reporting period begins and ends; 

4. the difference between the mean hourly rate of pay of employees in the reference category and employees in other gender categories;  

5. the difference between the median number of overtime hours of employees in the reference category and median number of overtime hours of employees in other gender categories who worked overtime hours; and 

6. the difference between the median amount of bonus pay of employees in the reference category who received bonus pay and median amount of bonus pay of employees in other gender categories. 

The Regulations provide a thorough walk-through for each calculation that is required to be in the report and can nearly be read as a step-by-step guide to preparing your workplaces pay transparency report. Additionally, the BC Government has created a Pay Transparency Reporting Tool available to employers through their Business BCeID account.  

The Act doesn’t impose monetary penalties for employers who do not publish pay transparency reports but employs a name and shame approach. The government may publicly identify employers who do not comply.  Key take away for all employers is to be aware of the new reporting requirement for all employers with 50 or more employees. 

If you have questions about this topic or any other workplace law issues, feel free to contact Rose Keith* or any member of our Workplace Law team. You can also stay informed by exploring our most recent blog posts here.