Pay Transparency in B.C.: A New Year Playbook for Job Postings, Pay Practices, and Reporting Readiness
Pay transparency compliance is no longer a “future HR project” in British Columbia. The British Columbia Pay Transparency Act, which became law on May 11, 2023, enforces requirements on public job postings and on how employers handle pay history questions and pay discussions in the workplace. It also introduced phased annual reporting obligations that expand to more employers each year.
This post outlines Greyston Law’s practical steps for B.C. employers to start 2026 with a low-friction compliance plan.
1. Confirm whether you will have to file a pay transparency report in 2026
Reporting is being implemented incrementally based on the number of employees employed in British Columbia as of January 1 of the reporting year. The phased thresholds are as follows:
By November 1, 2024: all employers with 1,000 employees in B.C. or more
By November 1, 2025: all employers with 300 employees in B.C. or more
By November 1, 2026: all employers with 50 employees in B.C. or more
If your organization reaches or exceeds the 50-employee threshold as of January 1, 2026, start compliance preparations early.
Even if your organization is not yet subject to reporting requirements, the daily policies outlined in the Act concerning job postings and remuneration practices may still be applicable.
2. Make job postings compliant: Publish the “expected pay” or “pay range”
B.C. employers must include the expected pay or pay range in all publicly advertised job postings. Best practices that reduce risk and recruiter friction include:
Stating the expected salary (for example, Salary: $63,000 per year) or using a realistic range tied to your compensation framework (for example, Salary: $63,000 - $91,000, depending on experience);
If compensation involves variable components, disclose the base range along with a clear qualifier (for example, plus bonus/commission eligibility) without undermining the base range.
Additionally, ensure internal approvals are aligned so hiring managers do not post outside approved bands and then attempt to “fix it later.”
3. Do not ask for pay history
The Act restricts using pay history as part of recruiting and hiring processes. Your compliance risk here is often unintentional: legacy interview guides, application forms, and recruiter habits. To reduce risk:
Remove salary history fields from application form templates;
Update recruiter and manager interview guides to prevent questions like “What are you making now?” and their indirect equivalents;
Train interviewers to reframe compensation discussions around expectations and range alignment, not past pay.
4. Revisit pay secrecy and reprisal risk: employees can discuss compensation
The Act also provides protections for employees discussing pay and restrictions on employer reprisal related to pay transparency rights. The high-risk situation is usually not “the policy' itself but rather 'the reaction”—for example, a manager discourages pay discussions or an employee claims they faced disadvantages after raising pay transparency concerns.
To promote compliance, employers should:
Remove or update any handbook language that discourages employees from talking about compensation;
Include a brief manager training module on how to respond when employees compare pay and when to escalate issues to HR;
Implement a neutral, standardized process for addressing internal pay concerns to ensure consistency.
Please note, these obligations apply only to provincially regulated B.C. employers; federally regulated employers follow a different framework.
5. If you will report in 2026: start with data readiness, not “gap fixing” in deadline week
The province provides a Pay Transparency Reporting Tool that generates a report from uploaded, non-identifiable data, but it is not a substitute for internal readiness: payroll codes, job families, and gender data governance must still be reliable. Below is Greyston Law’s data readiness checklist that you can set in place as the new calendar year begins:
Determine headcount threshold (employees working in B.C. as of January 1);
Confirm what data you have for:
Compensation (base, overtime, variable pay treatment);
Employee gender information (collection method, opt-out handling, privacy safeguards);
Assign internal ownership (HR, payroll, legal/privacy) and create an approvals workflow; and
Run a test export in the second quarter or early in the third quarter so you are not troubleshooting data definitions in October.
Need a pay transparency compliance tune-up?
Greyston Law advises B.C. employers on job posting templates, compensation governance, policy updates, manager training, and reporting readiness under the Pay Transparency Act.
Legal Disclaimer
This blog is provided for general informational purposes only and does not constitute legal advice. Employment law is fact-specific and varies by jurisdiction; you should obtain legal advice regarding your particular circumstances.
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