New Year’s update on federally regulated employer requirements

24 February 2026 6 min read

By Michaela Dennis, Samantha Roberts, Brianne Upshaw and Giovanna Di Sauro

At a glance

Updated notice and severance requirements for individual terminations.
Group terminations trigger 16‑week notice, detailed disclosures, and mandatory joint planning committees.
Pay Equity Act requires ongoing plans, gap corrections, annual filings, and 2029 update deadlines.
Accessible Canada Act mandates accessibility plans, feedback processes, progress reports, and enforcement penalties.

Going into the New Year, federally regulated employers should review and consider their compliance with federal labour and employment obligations, including termination entitlements, pay equity, and accessibility. A brief summary of key obligations in these areas is set out below.

Termination requirements under the Canada Labour Code

Recent changes to entitlements for individual terminations

Federally regulated employers must ensure that, if the employment of an individual employee is terminated without just cause, the employer provides notice of termination, or wages in lieu thereof.

Unless a greater period of notice is provided for under an individual contract of employment, the minimum notice period or wages in lieu thereof required by the Canada Labour Code is as follows:

two weeks, if the employee has completed at least three consecutive months of employment;
three weeks, if the employee has completed at least three consecutive years of employment;
four weeks, if the employee has completed at least four consecutive years of employment;
five weeks, if the employee has completed at least five consecutive years of employment;
six weeks, if the employee has completed at least six consecutive years of employment;
seven weeks, if the employee has completed at least seven consecutive years of employment; and
eight weeks, if the employee has completed at least eight consecutive years of employment.

A federally regulated employer must also give a terminated employee a written statement of benefits setting out vacation entitlements, wages, severance pay, and any other outstanding benefits as of the statement date. If providing notice of termination instead of wages in lieu thereof, the statement must be given as soon as possible and no later than two weeks before the termination date. If providing wages in lieu of notice, the statement must be given on or before the termination date.

As a reminder, an employee of a federally regulated employer who has completed twelve consecutive months of continuous employment and whose employment is terminated without just cause is generally entitled to severance pay equal to the greater of: (a) two days of the employee’s regular wages for each year of completed employment; or (b) five days of regular wages.

Recent changes to group terminations

In federally regulated workplaces, a group termination occurs if the employment of 50 or more employees at a single industrial establishment is terminated either on the same date or within any four-week period.

Under the Canada Labour Code, federally regulated employers must provide employees with specific notice and job planning committee requirements, which are in addition to the requirement to provide individual severance pay and individual notice of termination or wages in lieu thereof.

Notice requirements

When conducting a group termination, a federally regulated employer must give written notice at least 16 weeks before the first termination to the federal Head of Compliance and Enforcement.

Copies of the notice must be immediately provided to the federal Minister of Employment and Social Development, the Canadian Employment Insurance Commission, and, if applicable, the trade union of an affected employee. If an employee is not represented by a trade union, notice must either be given to the employee or posted in a conspicuous place within the workplace.

A notice of termination must include specific details, such as the intended termination date(s), estimated number of affected employees, employer name, location, any applicable trade union(s), and the reason for the termination.

Waivers may be requested and obtained in certain circumstances, but waivers will not exceed six months.

Joint planning committee

A specific feature of group terminations under the Canada Labour Code is that, within two weeks of providing group termination notice, an employer must establish and convene a joint planning committee. There are specific rules regarding the composition of the committee, when the committee must first meet, and the tasks it must complete.

Federal pay equity obligations

The federal Pay Equity Act applies to all federally regulated employers with ten or more employees. The Pay Equity Act addresses gender-based pay disparities by imposing ongoing obligations on federally regulated employers, including developing and updating a pay equity plan, correcting pay disparities between male and female employees doing work of equal value, and filing annual statements. Employers should be aware of their ongoing obligations and the upcoming deadlines under the Pay Equity Act.

Pay equity plan

The central feature of the federal Pay Equity Act is the requirement for employers to establish a pay equity plan. Employers were required to establish a pay equity plan, in accordance with the prescribed steps, by September 3, 2024, or within three years of becoming subject to the Pay Equity Act.

Employers with 100 or more employees, or those with unionized employees, must establish a pay equity committee to develop the pay equity plan. Employers that are not required to establish a committee may still do so voluntarily or at the request of an employee. The composition of the committee is prescribed by the federal Pay Equity Act.

Before finalizing the pay equity plan, the employer or committee must post the draft plan along with a notice to employees, allowing a 60-day period for employees to submit written feedback. The final pay equity plan must consider the employees’ feedback, and was required to be posted by September 3, 2024, or within three years of the employer becoming subject to the federal Pay Equity Act.

Correcting pay disparities

Within one day of posting the final pay equity plan, federally regulated employers subject to the federal Pay Equity Act must correct any pay gaps by increasing compensation to female job classes that are receiving less than the job classes of their male counterparts. Employers may phase in pay increases in some circumstances.

Ongoing obligations

Federally regulated employers must review and update their pay equity plan to identify and correct any new wage disparities, posting an updated plan by September 4, 2029, or on the fifth anniversary of the day on which the final pay equity plan was posted, and after that, at least every five years. Wage disparities identified by the updated plan must be corrected by September 5, 2029, or the day after the day on which the updated pay equity plan is posted.

Employers also have an ongoing obligation to file annual statements with the federal Pay Equity Commissioner. Due first on June 30, 2025, or June 30 of the calendar year after the employer has posted the final pay equity plan, and annually thereafter, employers must submit a declaration confirming their ongoing compliance with the federal Pay Equity Act.

Compliance with the Pay Equity Act is enforced by the Pay Equity Commissioner. Employers should be aware that failure to comply can result in significant monetary penalties.

Federal accessibility obligations

Federal accessibility requirements are governed by the federal Accessible Canada Act (ACA) and Accessible Canada Regulations (the Regulations). The ACA and its Regulations aim to identify, remove, and prevent barriers for all persons, particularly persons with disabilities, with the goal of achieving a Canada without barriers by January 1, 2040.

The ACA and its Regulations apply to federal public sector organizations and federally regulated private sector employers with ten or more employees. The ACA and its Regulations create three main obligations for employers:

Accessibility plan: Prepare and publish a plan describing policies, programs, practices, and services to identify, remove, and prevent barriers.
Feedback process: Establish and describe a process for receiving and addressing feedback on the accessibility plan and barriers encountered by employees or others interacting with the employer.
Progress reports: Prepare and publish reports on the implementation of the accessibility plan, including how feedback was considered.

Deadlines for employers to publish their first accessibility plan varied based on whether the organization was public or private and its size.

Additional obligations include notifying the Accessibility Commissioner within 48 hours of publishing accessibility plans, descriptions of the feedback process, and progress reports; consulting persons with disabilities when preparing accessibility plans and progress reports and describing the consultation process in the plans and reports; providing accessibility plans and progress reports in alternate formats upon request; and complying with record-keeping obligations.

Non‑compliance may result in enforcement by the Accessibility Commissioner, including monetary penalties, corrective measures, and public naming of violators.