Bill C-250 adds a new Division I.01 to the Canada Labour Code that requires employers to count specified pre-flight and post-flight duties, mandatory training, and time spent “at the call of the employer” (including during flight delays) as hours worked for the purposes of calculating pay under section 169. It also requires employers to pay flight attendants at least their regular rate of wages for that time.
The change converts several categories of work that have often been unpaid or treated as separate allowances into compensable hours, with direct effects on payroll, overtime calculations, rostering and collective-bargaining dynamics for federally regulated air carriers and the flight attendants they employ.
At a Glance
What It Does
The bill inserts section 177.01 into the Code making pre-flight/post-flight duties related to aircraft security and passenger service, mandatory training time, and time spent at the workplace at the employer’s call (including during delays) count as hours worked for purposes of section 169. It requires payment at no less than the employee’s regular rate for those hours.
Who It Affects
Federally regulated air carriers and any employer governed by the Canada Labour Code that employs flight attendants; flight attendants themselves; payroll and scheduling teams; and labour relations actors (unions and the Labour Program).
Why It Matters
This shifts previously ambiguous unpaid work into the paid-hours baseline, changing how overtime and work-time limits are calculated and reducing reliance on allowances or employer-designated unpaid time—a potentially material cost and compliance shift for carriers and a clarity-and-pay increase for crews.
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What This Bill Actually Does
The bill creates a new, flight-attendant–specific rule inside the Canada Labour Code. For the purpose of calculating hours worked under section 169, employers must now include time that flight attendants spend on pre-flight and post-flight duties tied to aircraft security and passenger service.
The bill lists examples—assisting with embarkation/disembarkation and pre-flight cabin and passenger safety checks—but the operative effect is to convert those categories from potential unpaid or allowance-type activities into compensable work time.
The bill separately requires employers to treat time spent completing mandatory training programs as hours worked. That covers classroom, simulator, or other employer-mandated training required for the job; the text does not define “mandatory training,” so whether employer-directed e‑learning or recurrent qualification events are covered will be an immediate implementation question.
The amendment also counts time when the employee is “in the workplace” and at the employer’s call and disposal as hours worked—explicitly including periods during flight delays regardless of whether the employer caused the delay.Finally, the bill mandates that employers pay flight attendants at least their regular rate of wages for the newly compensable time. Because the provision applies for purposes of section 169 (the Code’s hours‑of‑work and overtime calculation), including these periods in the hours‑worked denominator will affect overtime entitlement triggers and related premium calculations.
The bill does not set transition rules, an effective date, special overtime formulas, or exceptions for collective agreements, so those implementation topics will be resolved through regulation, labour relations, or adjudication under existing Code mechanisms.
The Five Things You Need to Know
Bill C-250 inserts Division I.01 and section 177.01 into the Canada Labour Code specifically for flight attendants.
It requires employers to include time spent on pre-flight and post-flight duties related to aircraft security and passenger service in hours worked, with the bill naming embarkation/disembarkation assistance and pre-flight cabin/passenger safety checks as examples.
The bill requires employers to include time flight attendants spend completing mandatory training programs as compensable hours.
Time spent in the workplace at the call and disposal of the employer—explicitly including time during flight delays, whether or not the delay is within the employer’s control—must be counted as hours worked.
Employers must pay flight attendants not less than their regular rate of wages for all the time described in the new subsection; the bill does not otherwise alter overtime multipliers or add new enforcement remedies.
Section-by-Section Breakdown
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Flight Attendants’ Remuneration Act
A single-line provision gives the amendment a short title: Flight Attendants’ Remuneration Act. That matters mostly for citation and for how regulators, employers and unions will refer to the change in contracts and policy documents; it does not affect substance or scope.
Creates a flight-attendant–specific subpart
The bill adds a dedicated division within the Code focused only on flight attendants. Mechanically, that isolates the rules so they apply to employees the employer designates as flight attendants under the Code regime. It also signals Parliament’s intent to treat flight-attendant duties differently from other occupational categories covered by the Code, which has implications for how inspectors and adjudicators interpret similar claims from other classes of employees.
What counts as hours worked: duties, training and workplace time
Subsection (1) has three distinct prongs. Paragraph (a) pulls in pre‑flight and post‑flight duties related to aircraft security and passenger service—items the bill expressly links to safety and service tasks. Paragraph (b) treats time spent on mandatory training programs as work; the lack of a definition of “mandatory” leaves scope questions for practice (e.g., employer‑directed periodic recertification vs. optional courses). Paragraph (c) makes time spent in the workplace at the employer’s call and disposal compensable and explicitly names flight delays as compensable time, regardless of causation. Practically, employers will need to map operational activities to these prongs to decide what to pay and when.
Wage-rate requirement for the newly compensable time
Subsection (2) requires payment at not less than the employee’s regular rate of wages for the time covered by subsection (1). It does not specify premium rates, overtime multipliers, allowances, per‑diems, or how the regular rate should be calculated where multiple pay components exist. That omission leaves room for disputes over whether premiums, shift differentials or allowances must be folded into the regular rate for these hours or whether they remain separate.
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Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Flight attendants — They receive clearer statutory entitlement to pay for pre/post‑flight security and passenger‑service tasks, mandatory training, and time spent at the employer’s call, which can increase take‑home pay and reduce unpaid on‑duty time.
- Unions representing flight attendants — The amendment establishes a statutory baseline that unions can use to press for improved contractual language, reducing reliance on case‑by‑case grievance wins to secure pay for routine safety and training work.
- Safety and compliance advocates — By compensating safety‑related duties and training, the bill aligns incentives so attendants are paid for tasks that contribute to passenger and cabin safety, potentially improving compliance with safety checklists.
- Payroll and HR professionals (in the long run) — Although implementation creates short‑term work, the rule provides a clear statutory standard that payroll systems can be programmed to follow, reducing ambiguity over which activities must be paid.
Who Bears the Cost
- Federally regulated air carriers (national and regional) — Employers will likely face higher labour costs from paying for training, pre/post duties and paid delay time, plus administrative costs to capture and pay those hours accurately.
- Smaller or thin‑margin operators and charter firms — These carriers have less ability to absorb higher payroll costs and may respond by changing schedules, reducing routes, or restructuring work practices.
- Employers’ labour relations and operations teams — They must redesign rostering, timekeeping and training delivery (for example shifting more training off‑site or altering timing) to manage costs and compliance.
- The Labour Program and adjudicative bodies — Enforcement, complaint handling and potential adjudication of disputes over scope (what is “mandatory” training, when pre/post duties begin/end) will consume regulator and tribunal resources.
Key Issues
The Core Tension
The central dilemma is between ensuring fair compensation and safety incentives for flight attendants—by converting safety, service and training activities into paid work—and the operational and financial burden that such conversion imposes on carriers, particularly smaller operators; clarity and worker protection come at the price of higher labour costs and more complex rostering, and the bill leaves key definitional and implementation choices unresolved.
Several implementation uncertainties could blunt or complicate the bill’s effect. First, the statute does not define “flight attendant,” “mandatory training programs,” or the precise start/stop points for pre‑flight and post‑flight duties; those definitional gaps will quickly become the focus of grievances and inspector guidance.
Second, the interaction with the Code’s existing overtime framework is ambiguous: because the amendment changes what counts as hours worked under section 169, it will affect overtime eligibility and calculations, but the bill does not address whether premium pay rates (overtime multipliers, shift differentials, allowances) must be included in the “regular rate” used here. That can produce disputes over premium integration and retroactivity.
Operationally, the rule that delays are compensable “whether or not the delay is within the employer’s control” creates a significant cost exposure for carriers on weather‑ and ATC‑prone routes, potentially prompting changes to rostering practices or staffing buffers. Employers may seek to limit exposure by narrowing the scope of what they label as “mandatory” or by restructuring training delivery (e.g., unpaid off‑duty e‑learning), creating a gap between statutory intent and practice.
Finally, the bill is silent on transitional timing, exemptions, or how it interacts with collective‑agreement language—meaning parties will resolve many details through bargaining, administrative interpretation, or labor adjudication rather than by statutory clarity.
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