Guidance for preparing pay transparency reports

Section 6 of the Act requires employers to collect gender information from employees for the purposes of preparing a report. It is recommended that B.C.’s Gender and Sex Data Standard (PDF, 192KB) be used. When people can self-identify their gender, employers can engage with them in an inclusive, safe and respectful way. Gender is how a person identifies as a boy/man, girl/woman, or a blend of both or neither. Please read the Gender and Sex Data Standard Guidelines (PDF, 384KB) for help using the standard.

When collecting gender information for the pay transparency report, keep in mind that:

• Reasonable efforts must be made
• Employees should be notified that the collection is for the purpose of preparing a pay transparency report
• Employees can voluntarily provide gender information
• If an employee chooses not to provide their gender, their pay information will still be used in the report and their gender will be marked as unknown (per B.C.’s Gender and Sex Data Standard)
• Collection through a survey (which can be combined with other employee surveys) or via self-serve HR/payroll software is common and acceptable

Employers must collect and manage personal information in compliance with the Freedom of Information and Protection of Privacy Act or the Personal Information Protection Act.

Use the following gender codes as provided by the employee:

• M = Man
• W or F = Woman
• X = Non-Binary
• U = Unknown or prefer not to say

Pay transparency reports must include the following employer information:

• Name of organization
• Mailing address
• Applicable North American Industry Classification System (NAICS) code
• The start and end date of the 12-month reporting period (the employer can choose either the most recently completed fiscal or calendar year)
• Number of employees as of January 1 of the reporting year expressed in the following ranges:
  • 50 to 299 employees;
  • 300 to 999 employees;
  • 1000 or more employees;

Section 3 of the Regulation outlines all the information that must be included in the employer’s report.

A template comma-separated value (CSV) file is available to organize employees’ data for the 12-month reporting period.

The following data must be in the report calculations:

• Gender classification
• Hours worked
• Ordinary pay (salary)
• Special salary
• Overtime hours
• Overtime pay
• Bonus pay

Include all employees who were paid during the reporting period, regardless of hours worked or employment status, such as full-time, part-time, seasonal, temporary, or any other category.

Pay gaps are reported as a percentage between the gender category Man and the other three gender categories. To preserve privacy, data should be suppressed if there are less than 10 individuals in a gender category; this will occur automatically if using the Pay Transparency Reporting Tool. If there are fewer than 10 in the gender category Man, an alternative reference category must be chosen per the Regulation.

Hours worked is the number of hours an employee is paid, which can be attributed to the salary. This includes hours on paid leave calculated at a 100% rate.

For employees whose hours of work are not recorded, an alternative way to represent hours worked may be used such as:

• Conversion formula, or
• Alternate record of hours (such as from a logging device or logbook)

Ordinary pay, or salary is money paid for hours worked before deductions.

Ordinary pay includes:

• Paid leaves such as vacation and other paid leaves when the employee is paid at 100% of salary
• Premiums that are not overtime pay or an allowance
• Overtime that can be banked and then taken as time off
• Statutory holiday pay

Ordinary pay does not include: (and should not be included in the reporting data)

• Benefits, including taxable benefits
• Reimbursement for employment related expenses
• Severance pay or termination pay
• Vacation payouts when not taken as leave
• Retroactive payments for commitments outside the reporting period
• Securities
• Allowances
  • An allowance is any payment to support the duties of the employee’s employment that meets all of the following criteria:
    • the amount paid is predetermined,
    • the amount is paid for a certain purpose, and
    • the amount paid is at the sole disposition of the employee receiving the payment.
  • These can include payments made for:
    • accommodation
    • transportation
    • materials
    • meals, or
    • cost differences between remote and other locations, if working in isolated locations.

Pay gap calculations can be found in the Pay Transparency Regulation:

• Mean hourly rates of pay (section 5)
• Median hourly rates of pay (section 6)

Special salary is intended for rare situations where an employee is paid a lump sum and determining the hours worked is challenging. In such cases, the employer may need to estimate the approximate number of hours worked and calculate the estimated hourly rate.

Special salary should not be used for:

• Ordinary pay
• Allowances
• Benefits, including taxable benefits
• Reimbursement for employment related expenses
• Severance pay or termination pay
• Vacation payouts when not taken as leave
• Retroactive payments for commitments outside the reporting period
• Securities

Overtime hours

The number of overtime hours related to overtime pay should be reported as overtime hours.

Overtime Pay

Overtime pay is:

• Money paid to an employee for hours worked in excess of the employee's usual hours of work
• Based on a rate of pay that is at least 1.5 times the usual rate

Include overtime pay that has been paid within the 12-month reporting period, rather than when it was worked.

When calculating pay gaps, the total amount of overtime pay should be used instead of the hourly rate, and only individuals with overtime pay should be included.

Pay gap calculations can be found in the Pay Transparency Regulation:

• Mean overtime pay (section 7)
• Median overtime pay (section 8)
• Mean number of overtime hours (section 9)
• Median number of overtime hours (section 10)

Bonus pay is any additional remuneration paid to an employee.

Bonus pay types

Include if an employee receives a bonus as a result of:

• Profit sharing
• Increased productivity
• Increased performance
• Commissions
• Referral bonus
• Signing bonus
• Other incentives that depend on the organization’s profitability

If employees receive payments in addition to their ordinary pay as automatic rewards, these should be reported as bonus pay.

Non-monetary bonuses

Include bonuses that are vested and paid such as:

• Stocks
• Shares
• Any other types of equity compensation

Include bonus pay that has been paid within the 12-month reporting period, rather than when it was worked.

Pay gap calculations can be found in the Pay Transparency Regulation:

• Mean bonus pay (section 11)
• Median bonus pay (section 12)

1. Log in to the Pay Transparency Reporting Tool with the Business BCeID.
2. Click on ‘Upload your CSV here’
3. Enter the organization’s information in the required fields. Optional fields can also be filled.
4. Employer Name & Address will be automatically populated based on the BCeID profile. Please ensure the information is accurate.
5. NAICS Code or the North American Industry Classification System represents a sector; select the one that best represents the organization. If multiple sectors apply, select the code that covers the majority of employees.
6. Employee Count Range should be the number of employees as of January 1 of the reporting year. Choose from:
   • 50 to 299 employees
   • 300 to 999 employees
   • 1,000 or more employees
7. Reporting Year should reflect the year the organization is reporting on. Choose from the dropdown menu.
8. Time Period is the 12-month period linked to the reporting data. The employer can choose either the most recently completed calendar year or financial year. Select the starting month and year to the ending month and year.
9. Employer Statement (optional) can be filled out with general information about the organization.
10. Data Constraints (optional) can be filled with relevant information, such as limitations, constraints, or dependencies, that may help explain the reporting data.
11. File Upload is where a CSV file can be uploaded. Click on ‘Upload file’ and choose the appropriate CSV file. Once the file name appears, click on ‘Generate Draft Report’. Any errors in the CSV file will be displayed with the line number where the error has occurred. Please correct any errors in the CSV file and re-upload.
12. If there are no errors in the CSV file, a draft report will be displayed. Please review it to ensure it shows the correct information.
13. Scroll to the bottom of the page and check the box that says, “I am ready to create a final report…”.
14. Click on the ‘Generate Final Report’ button.
15. A message will show stating that a pay transparency report was created. Click on the ‘Download PDF’ button to save a copy.

Important note: Finalizing a report in the tool does not meet the requirements of the Pay Transparency Act and the tool does not “submit” a report. Follow step 6 to meet the requirements.

• If an error message “Special Salary must contain data when Hours Worked and Ordinary Pay do not contain data” shows, make sure:
  • Bonus pay is not the only entry in a row
  • Overtime is not the only entry in a row
  • The data doesn’t include rows that are all 0s
• If an error message “Hours Worked / Ordinary Pay must not contain data when Special Salary contains data” shows, remove data from ordinary pay or special salary as special salary cannot be combined with other pay types and should only be used on its own per employee.
• If independent calculations do not match the reporting tool draft report, please refer to the Pay Transparency Report Calculation Instruction or the Regulation for the correct method.
• If the mailing address on the draft report is incorrect, please contact Service BC Help Desk to update as this is pulled from Business BCeID.
• The report format such as colours and layout cannot be changed in the reporting tool but customization may occur outside of the tool.
• When preparing a CSV file for the reporting tool, enter numeric values only and do not use dollar signs or commas. Enter 0 or leave blank for cells with no data.
• If a row contains no data (all 0s or blank), remove it from the reporting data.
• Employers will have 30 days to edit the finalized report.