Special thanks to our articling student Brianna Grieff for contributing to this update.

As pay transparency obligations continue to expand globally, employers with operations in Canada should be paying close attention to a rapidly evolving provincial landscape. Much like developments across the European Union, the United Kingdom, and numerous US states, Canadian jurisdictions are increasingly adopting measures designed to promote pay equity and greater transparency in compensation practices. These measures include salary disclosure requirements in job postings, restrictions on salary history inquiries, employee protections related to pay discussions, and, in some jurisdictions, pay transparency reporting obligations.

For US-based multinational employers, Canada presents both familiar challenges and unique compliance considerations. While Canada does not yet have a single nationwide pay transparency framework, a growing number of provinces have enacted or proposed legislation that requires employers to revisit recruiting practices, compensation governance, pay equity analyses, and data collection processes. As a result, organizations operating across multiple Canadian jurisdictions may find themselves managing another layer of regulatory complexity alongside existing US, EU, and UK transparency requirements.

The trend is gaining momentum. Recent developments in New Brunswick, together with existing requirements in British Columbia, Prince Edward Island, Ontario, and other provinces, reflect a growing expectation that employers provide greater visibility into compensation practices and be prepared to explain and defend pay differentials.

Below, we summarize the current pay transparency landscape across Canada and the key considerations for employers with Canadian workforces.

New Brunswick: The Latest Province to Act

New Brunswick recently joined the growing list of provinces imposing pay transparency requirements.