The Pay Equity Act, in plain terms
Quebec's Loi sur l'équité salariale requires employers with 10 or more employees to identify whether jobs traditionally or predominantly done by women are paid less than jobs of equivalent value traditionally or predominantly done by men — and to correct the gap if one exists. It doesn't compare men to women as individuals; it compares job categories by predominance and by evaluated value.
The core mechanics of the Act have been stable for some time — the last substantive amendments took effect in April 2019 (retroactive adjustment dates, an employee-participation process, a 6-year document retention rule, and a formal CNESST complaint form). What has changed more recently is timing: a large share of Quebec employers are now mid-way through a mandatory 5-year maintenance cycle, and CNESST has meaningfully increased outreach and enforcement.
What's new recently
The process, step by step
Initial exercise (once, when first covered)
- Confirm you average 10+ employees across the reference year
- Determine company size band (10–49 / 50–99 / 100+) — this sets whether a pay equity committee is required
- Identify job categories and each category's gender predominance
- Choose an evaluation method (CNESST's 4-factor point method or an equivalent)
- Evaluate each category and calculate point totals
- Calculate wage gaps between comparable female- and male-predominant categories
- Post the results for 60 days so employees can review them
- Pay retroactive adjustments back to the date of the underlying event
- File the DEMES declaration with CNESST
Maintenance (every 5 years, ongoing)
- Identify the date the next maintenance evaluation is due (5 years from the last posting)
- Log events since the last exercise that could affect equity (new roles, restructured pay, changed duties)
- Re-check job category predominance and evaluate any new/changed categories
- Recalculate wage gaps and correct any new ones, retroactive to the triggering event
- Post updated results and keep supporting documents for 6 years
- File the updated DEMES declaration
A common misconception: male-dominated workforces
Employers in male-dominated industries sometimes assume that, because there's no clearly female-predominant job category, male vs. female headcount within a mixed category can be the basis for comparison instead. Under the Act, that's not quite how it works: the comparison is job category to job category (grouped by predominance and evaluated value), not headcount by gender within one mixed category. If, after properly applying the predominance test (see CNESST's rules on how predominance is determined — historical composition, current composition, and job-content stereotyping all matter), there truly are no female-predominant categories, the exercise can conclude at the "identify categories" step with a documented finding of no female-predominant categories — but that determination should be made carefully and, ideally, reviewed with counsel, since it's a common area of CNESST scrutiny.
Company profile
These fields feed the DEMES declaration and drive the applicability logic below. Everything on this page autosaves in your browser.
Applicability & obligations (auto-calculated)
Who doesn't count toward the 10-employee threshold
Per CNESST guidance, some people don't count toward your average headcount for applicability purposes — for example interns, students, and senior management. Confirm current guidance before relying on this for a borderline headcount.
Job category evaluation
CNESST's evaluation method scores every job category on 4 factors, each split into sub-factors, each scored on levels (typically 1–7). Multiply level by the sub-factor's share of the point pool to get a score, then sum for a total. Categories with similar totals are considered comparable in value.
See CNESST's own worked example (Directrice des ventes / Sales Director)
This is CNESST's published illustration of the method — reproduced here as a reference, not part of your data. It shows a female-predominant "Sales Director" category scored across the 4 factors and 10 standard sub-factors used in CNESST's own online tool, MonÉquitéSalariale.
| Factor — sub-factor | Level (of 7) | Rationale (CNESST's example) |
|---|---|---|
| Qualifications — Education/training | 7 | Undergraduate university degree |
| Qualifications — Experience | 6 | 3 to under 5 years |
| Qualifications — Dexterity & coordination | 1 | Precision/speed not essential |
| Responsibilities — Accountability | 5 | Major consequences of decisions/actions |
| Responsibilities — Communications | 5 | Persuading/negotiating: presenting arguments to convince others |
| Responsibilities — Supervision | 4 | Supervising: planning work, setting requirements, evaluating performance |
| Effort — Mental/intellectual effort | 4 | Complex job requiring high autonomy and judgment |
| Effort — Concentration & sensory attention | 2 | Low concentration/sensory demand under normal conditions |
| Effort — Physical effort | 1 | Very low physical effort |
| Working conditions — Discomfort & risk | 3 | Moderate level of inconvenience |
CNESST's recognized weighting ranges: Qualifications 20–35%, Responsibilities 25–30%, Effort 20–40%, Working conditions 5–15%. Weightings must not systematically favour male-predominant categories — review your highest and lowest-weighted sub-factors for that risk before finalizing.
1 · Set your factor weightings
Must total 100%. Defaults sit inside CNESST's recognized ranges — adjust to reflect your organization, but stay within the bounds shown, and document why.
2 · Your job categories
Add every job category in the organization, its predominance, and a level (1–7) for each of the 10 sub-factors. Points are calculated automatically from the weightings above.
| Job category | Predominance | Headcount | Educ. | Exp. | Dext. | Account. | Comm. | Superv. | Mental | Focus | Physical | Conditions | Points |
|---|
Wage gap & adjustments
Enter each category's total hourly remuneration (salary + flexible pay like tips/bonuses + the value of benefits, divided by normal weekly hours). The tool builds a simple wage line from your male-predominant categories (points vs. rate) and compares each female-predominant category against it at its own point total — a simplified version of CNESST's "global method" wage curve. Only male-predominant categories can be used to correct a gap; a male-predominant category's pay can never be reduced to close one.
Hourly total remuneration by category
| Job category | Predominance | Points | Hourly total remuneration ($) |
|---|
Gap analysis
Compliance tracker
Dates in italics are calculated from the Company Profile tab where possible. Check items off as completed — this list autosaves.
Add a custom tracked item
DEMES submission checklist
CNESST requires the following information when you file the DEMES (Déclaration de l'employeur en matière d'équité salariale) — this must be filed even if the underlying exercise isn't finished yet. This tab pulls what it can from Company Profile and flags what's still missing.