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In Québec, pay equity is not something you do once and forget. The Pay Equity Act sets several deadlines, and each one has its own date [1]. Here are the main ones, explained simply.
The deadlines at a glance
| Deadline | When | Source |
|---|---|---|
| Check the size of the company | Every year, as long as the company has fewer than 10 employees | [2] [3] |
| Complete the initial exercise | Generally within 4 years after reaching 10 employees | [2] |
| Receive comments after the posting | For 60 days after the first posting | [1] |
| Make the second posting | Within 30 days after those 60 days | [1] |
| Evaluate maintenance | Every 5 years, from the date of the last posting | [1] [4] |
| Complete the participation process (if required) | No later than 60 days before the maintenance posting | [5] |
| File the DEMES | Within 6 months after the end of the fiscal year | [6] |
| Keep the documents | At least 6 years | [6] [8] |
1. Knowing whether your company is covered
The Act applies to Québec-regulated companies with an average of 10 or more employees [1] [3]. As long as you are below that threshold, the check is repeated every year.
As soon as you reach 10 employees, your company is covered for good. Even if you later drop below 10, the obligations remain [2] [3]. Part-time and seasonal staff count too.
2. The initial exercise: 4 years to complete it
Once the threshold of 10 is reached, the Act generally provides 4 years to complete the initial exercise [2]. This is the first time the company checks whether jobs held mostly by women are paid less than jobs held mostly by men that have the same value.
Four years seems like a long time. But in a growing company, time goes by quickly. And missing the deadline does not make the obligation go away.
3. Postings: 60 days, then 30 days
At the end of the exercise, the results must be posted in a place everyone can see [1]. Then:
- For 60 days, employees can ask questions or make comments.
- Within the following 30 days, the employer makes a second posting. It shows what changed following the comments, or that no change was needed [1].
The posting date matters: it is the starting point for the next deadline [4].
4. Maintenance: every 5 years
Pay equity must be re-evaluated every 5 years. This is called the maintenance evaluation [1]. The date is not the same for every company: it is calculated from the posting date of your last work [4].
For example, a company that posted its last maintenance evaluation in June 2022 has its next deadline in June 2027.
Watch out for delays. Since 2019, pay adjustments are owed from the date of the event that created the gap, not from the posting date [5]. A change that happened 3 years ago can therefore lead to 3 years of retroactive adjustments [4].
5. The participation process: 60 days before the posting
In some cases, for example when there is a union and the employer carries out the maintenance evaluation alone, the Act provides a process to inform and consult employees. This process must be completed no later than 60 days before the maintenance results are posted [5].
6. The DEMES: within 6 months after the end of the fiscal year
The DEMES is the employer pay equity statement. It informs the CNESST of the progress of your work. For a private company, it is generally filed within 6 months after the end of the fiscal year, at the same time as the annual update with the Registraire des entreprises [6].
It is filed every year until the initial exercise is completed, then with each maintenance evaluation [6]. Failing to file it can lead to a fine of $1,000 to $45,000 [3] [6].
7. Documents: keep them at least 6 years
The data, decisions and results of your work must be kept for at least 6 years [6] [8]. They may be requested during a CNESST audit or in the event of a complaint.
In short. In Québec, pay equity follows a precise calendar: an initial exercise, postings of 60 and 30 days, a maintenance evaluation every 5 years and a DEMES within 6 months after the end of the fiscal year. The date of your last posting is the most important one to remember.
An often forgotten calendar
These deadlines often go unnoticed. According to the CNESST, as of December 31, 2025, only 65.3% of the 25,310 employers that were due to have completed their second maintenance evaluation reported having done so [7].
For a full overview of the obligations, see our complete guide to pay equity in Québec. Want to know where you stand? Our pay equity diagnostic gives you a first picture in 2 minutes. And if you would rather not handle it yourself, Leduc HR's specialists can take care of your pay equity from start to finish.
This article is for information purposes only. It is neither legal advice nor professional advice. Exact deadlines depend on each company's situation. For your specific obligations, refer to the Act, the CNESST and your legal advisors.
Sources
- Pay Equity Act, CQLR, c. E-12.001, LégisQuébec
- Pay equity obligations by company size, Leduc HR, based on the Act and the CNESST
- Aide-mémoire des obligations de l'employeur selon le nombre de travailleuses et travailleurs (in French), CNESST
- Pay equity maintenance: common mistakes, Leduc HR, based on the Act and the CNESST
- Act to amend the Pay Equity Act mainly to improve the evaluation of pay equity maintenance (2019, c. 4) (in French), Gazette officielle du Québec
- The DEMES: Quebec's employer pay equity statement, Leduc HR, based on the CNESST
- L'équité salariale en chiffres, data as of December 31, 2025 (in French), CNESST
- CNESST pay equity audit: what to expect, Leduc HR, based on the CNESST
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