HALTING THE EXPANSION OF PAY TRANSPARENCY REPORTING REQUIREMENTS FOR SMALL AND MID-SIZED EMPLOYERS (2026)

Issue

The B.C. Pay Transparency Act is scheduled to expand mandatory public pay transparency reporting to employers with 50 or more employees beginning in November 2026. While improving pay equity is an important and widely supported objective, the value of pay transparency reporting depends on the availability of robust and reliable data. Larger employers are better positioned to generate meaningful insights, while smaller and mid-sized businesses often lack the workforce size needed to produce statistically valid comparisons. Extending the requirement to these employers will impose disproportionate administrative burdens while frequently resulting in incomplete or low-value reporting. The province should halt the rollout at the current 300-employee threshold.

Background

The Pay Transparency Act introduced measures intended to advance gender pay equity in B.C. workplaces. While the business community supports efforts that promote fairness and equal opportunity in the labour market, the requirement for all employers above a certain size to complete and publish a pay transparency report each year is an undue burden on small and mid-sized employers.

Since 2023, employers of certain sizes have been required to issue annual pay transparency reports outlining gender-based pay gaps in compensation. Initially, this only applied to the Government and its six largest Crown Corporations, but it has expanded each year to include businesses with over 1,000 employees (in 2024) and then businesses with over 300 employees (in 2025). As of November 1, 2026, all businesses with between 50 – 299 employees will be required to develop and then publish publicly a pay transparency report. Importantly, “employee” is defined as anyone working for the business in BC, including both full-time and part-time employees.

To comply, employers must annually survey employees on their gender identity, track hours worked and compensation in all forms, maintain these secure records, update payroll or HR systems, and then produce and publicly post annual reports outlining compensation by gender.   For many small and mid-sized businesses, this will require new administrative processes, potential system upgrades, and additional compliance costs at a time when firms are already managing elevated input and labour expenses.  These businesses often lack dedicated HR capacity and the technical systems required to efficiently collect, manage, and report the required gender and compensation data.

At the same time, the policy value of expanding reporting to this segment is limited. Many employers of this size will have too few employees in one or more gender categories to produce statistically meaningful comparisons. Because the regulation requires suppression of data where fewer than 10 employees exist in a category, reports may contain little to no actionable information despite imposing the full administrative burden on the employer. This results in compliance costs without delivering meaningful insight into potential pay inequities.

The Pay Transparency Act already provides government with authority to exempt employers by regulation. Maintaining the current threshold would preserve the policy’s focus on large employers—where data is most robust, any potential impact the greatest, and administrative capacity is strongest—while avoiding unnecessary burden on small and mid-sized businesses that form the backbone of BC’s economy.

The Chamber Recommends

That the Provincial Government:

1. Halt the planned expansion of mandatory Pay Transparency Act reporting to smaller employers and maintain the current reporting threshold at 300 or more employees.