Pay Equity Commissioner’s decision letter regarding the application for extension to post the final pay equity plan
Treasury Board of Canada Secretariat on behalf of the Royal Canadian Mounted Police
File number: ARDA-2026-0014
Decision: 2026-LD-PEC-062
Nature of the application
The Treasury Board of Canada Secretariat (TBS) on behalf of the Treasury Board of Canada as the employer of civilian and regular members of the Royal Canadian Mounted Police (RCMP) was granted an extension until , to post its final pay equity plan (2024-LD-PEC-05).
In this application, TBS says that despite having made progress in advancing its pay equity exercise, a significant amount of work remains to be completed, and it is seeking an additional extension until .
The affected workplace parties—Public Service Alliance of Canada, Professional Institute of the Public Service, National Police Federation, Canadian Association of Professional Employees, Canadian Union of Public Employees – Local 104, and the non-unionized employee representative—were given an opportunity to provide representations. None did so.
Summary of decision
TBS’s request for an extension to post its final pay equity plan is granted in 6-month increments, conditional on measurable progress being made during each increment. The total extension period will not exceed the requested timeline ending on .
Analysis
The RCMP is a large organization with a complex workforce spread across Canada and abroad. It expects that its pay equity plan will include about 21,400 members and 144 job classes.
At the time of its first extension application, TBS had established the pay equity committee for the RCMP (the Committee), and the Committee had identified the job classes and determined their gender predominance. TBS says that since then, despite considerable work, it has encountered several unanticipated challenges. It explains that it underestimated how long certain elements of the pay equity exercise would take in its original extension request. For example, it estimated that it would take three months to collect the job information needed to conduct the valuation of work. However, there were significant gaps in that information, which required the creation of a new data collection survey that will instead take 20 months to develop, pilot, adjust, and implement. It offered other examples related to compensation data that reflected a similar disparity.
TBS also explains that there were challenges with the transmission of sensitive information between TBS, the RCMP, and the Committee that required the establishment of a secure platform for information sharing, which contributed to delays.
To mitigate some of those challenges, TBS says that the Committee has increased the frequency of its meetings, including time for employee representatives to caucus. It provided a chronology demonstrating sustained activity by both itself and the Committee between and .
TBS notes that it has allocated seven resources to work exclusively on the RCMP’s pay equity exercise along with support from others working on all of TBS’s pay equity plans. It has provided a detailed workplan and timeline setting out how the Committee will complete the pay equity exercise by .
TBS acknowledges that this work is a priority and that while it is committed to developing the plan as quickly as possible with the Committee, it does not want the work to be rushed. It says that doing so risks errors or omissions in the plan that would jeopardize its ability to accurately identify and redress gender-based compensation gaps and then maintain that over time. It also notes the importance of ensuring the Committee continues to work collaboratively on a timeline that will allow it to be most productive. It cautions that without meaningful Committee involvement, it would likely receive “copious comments” on the draft plan from RCMP members, and that unaddressed comments could result in complaints.
Finally, TBS states that employees in female predominant job classes, and those who were employed as of , but have since resigned or retired, will be provided all lump sum payments with interest that they are entitled to.
Decision
I have reviewed and carefully considered all materials submitted as part of this application. I also take note of the fact that none of the affected workplace parties expressed concerns with this proposed extension.
I accept that TBS underestimated the time required for the Committee to complete the pay equity exercise but that with the advice of a contractor, its workplan and timeline reflect a realistic assessment of how long it will take to complete its pay equity exercise. I also accept that the Committee is working collaboratively and that rushing its work runs the risk of embedding errors and omissions into the RCMP’s foundational plan.
That said, the proposed deadline is almost five years beyond the legislated deadline. This means that employees—in particular women—in job classes where increases are found to be due will continue to experience the effect of a discriminatory pay system that the Pay Equity Act (Act) was designed to correct on a specific timeline. While I agree with TBS that affected employees are entitled to receive lump sum and interest payments back to the , deadline, there nonetheless needs to be a reliable end point.
As such, I am granting the extension in 6-month increments conditional on measurable progress being made during each increment, with the final increment ending on . At the end of each increment, TBS must report on its progress, identify any new challenges that might impede its ability to meet the milestones, and explain the steps it will take to mitigate them and stay on the authorized timeline.
Based on TBS’s workplan and timeline, the work that is to be carried out in each increment is as follows — note the first increment is retroactive to the date of this application and is therefore 8 months:
First Increment - to :
- Complete survey design, administration logistics and communications strategy
- Pilot survey and adjust
- Gather compensation data
- Develop calculation methods
- Provide update by:
Second Increment - to :
- Launch survey (employees to complete)
- Continue gathering compensation data
- Continue developing calculation methods
- Provide update by:
Third Increment - to :
- Validate survey results (management/trusted sources)
- Compile, review and summarize collected data
- Complete gathering compensation data
- Complete developing calculation methods
- Provide update by:
Fourth Increment – to :
- Determine value of work for all job classes
- Quality assurance review (“sore-thumbing”) of survey results
- Finalize inclusion/exclusion of five elements of compensation
- Complete calculation of compensation
- Provide update by:
Fifth Increment – to :
- Compare compensation
- Provide update by:
Sixth Increment – to :
- Prepare and post draft pay equity plan
- Adjust based on employee comments
- Post final pay equity plan
- Provide confirmation of posting by:
Given the amount of resources TBS has dedicated to this exercise, its commitment to retain mediators should the Committee face difficulties reaching consensus, the Committee’s willingness to adapt the frequency of its meetings to sustain progress, and the support of the contractor, I am optimistic that TBS and the Committee will collaboratively meet this new deadline. However, failure to demonstrate satisfactory progress at any stage may result in the denial of the extension request and the initiation of enforcement action to ensure compliance with the Act, including the issuance of administrative monetary penalties.
I will retain jurisdiction over this application and the increment timeline and reporting requirements until the final plan is posted.
TBS must still respect the remaining requirements under the Act, including, without limitation, the requirement of section 62.
TBS is required to share this letter with all parties in the workplace who may be affected by this decision.
Lori Straznicky
Pay Equity Commissioner