Every year, companies believe they are submitting accurate wage declarations to the CNESST. The numbers add up, and everything seems normal. Until the day the CNESST takes a closer look.
The wage report is not just an administrative exercise to be completed before March 15. The CNESST will then freeze its reading of your company for 2025 and use it to calculate contributions for the coming years. If its data no longer reflects your operational reality, that's where the discrepancy will begin.
Simplicity does not always equal compliance
The same logic often applies: act as simply as possible, report as you did the previous year, group similar items together, as long as the amounts “look right.”
However, organizations evolve faster than forms. Their structures change, positions change, tasks change, and ways of working are no longer quite the same as they were a few years ago. But when the declaration remains static while reality has evolved, the contribution no longer accurately reflects the company. Whether too high or too low, a misaligned contribution weakens the case. A solid declaration is measured by its ability to withstand verification.
Nuances that must be considered
Let's take an example. Paul is the production team manager. On paper, this is an office position. So, the reflex would be to report his salary in the administrative unit. However, Paul goes to the shop floor, supervises operations, and intervenes when issues arise. In short, he is exposed to the reality of the field.
In these circumstances, can their salary be declared as 100% administrative?
Sometimes yes. Sometimes no. Often, the answer is more nuanced. It is not a question of optimization, but of accurately reflecting the reality of the position as it existed during the year of the declaration, not as it exists today.
It should also be noted that in some areas, the line becomes blurred.
- Construction: Grouping trades together for the sake of simplicity seems logical... until the CNESST compares the payroll, the declared activities, and the reality of the construction sites. Simplification then becomes a problem.
- Transportation: Drivers often work outside Quebec. One might therefore think that their activity is not subject to CNESST jurisdiction. In fact, it all depends on the affiliation, the organization of the work, and the actual link with the Quebec employer.
- Self-employed workers: An invoice with tax numbers is not sufficient. When the worker is integrated into operations, uses company equipment, or works under supervision, the CNESST may conclude that the relationship is comparable to that of an employee.
The annual insurable maximum is another underestimated aspect. For most employers, it applies annually per worker; the excess portion must be excluded. In certain sectors, including construction, the maximum may apply on a weekly basis if certain conditions are met.
Are your activities changing? Notify the CNESST
When activities change, employers must quickly notify the CNESST. Deadlines exist depending on the nature of the change. Waiting until the next annual declaration is often a mistake. The declaration will confirm a reality that may no longer be valid. The CNESST does not guess, it relies on what is declared to it.
Trigger signals
On their own, certain situations do not constitute a fault: active experience file with no declared salary; significant variations in payroll between classification units; reporting logic changing from one year to the next; activities modified without prior notice. Together, however, they can raise doubts.
Even if the total “balances” with the RL-1 slips, an inconsistency quickly becomes apparent upon analysis.
Of course, there are situations of optimization. However, most files are compliant. Correcting an inherited logic, an approximation, or a declaration that no longer reflects reality is not sexy, but it often has the most lasting impact in terms of compliance.
Help that makes a difference
Is a CNESST financial inspector coming to visit? This is not the time to improvise.
Having your Lussier advisor involved from the outset will guide the discussions and ensure a structured and consistent review of the file.
A clear and defensible declaration is always easier to explain than an approximate one. This way, the March 15 deadline will become an opportunity to verify that your 2025 wage statement truly reflects your company's structure. All in the spirit of fairness and consistency, and to ensure that your data is justifiable.
Let's review your statement together, validate its compliance, and then structure it appropriately for subsequent years.
A second look at the right time often eliminates costly adjustments later. Consult us at financementsst@lussier.co before submitting your return. It's always better than when the CNESST decides to take a closer look.
Mathieu Carrière
Senior Director – Employee Benefits
