Shedding Light on the Sunshine List

Sunrise: A song of many humans – A brief history

The Ontario Public Sector Salary Disclosure (“PSSD”), colloquially known as the “Sunshine List”, has just been released for the 2025 year. Before too long, there will be numerous articles about its size, usefulness, and its long history (almost 30 years old!).

The dawn of the Sunshine List came about in the mid-90s, as part of then premier Mike Harris’s “Common Sense Revolution”. The idea was that a public list of high government (or government-funded) salaries, $100K or more, would be a useful check against public sector payroll costs and could hold senior government leaders accountable. “Sunshine is the best disinfectant”, as the saying goes.

The first version of the Sunshine List covered the year 1996 and it listed 4,501 individuals. At the time, it included professors, lawyers, judges, doctors and executives. The highest paid individual was the head of Ontario Hydro. The President & CEO of Sick Kids was in the top 10. The list contained one executive assistant. Dozens of hospitals that still operate today didn’t have anyone that qualified for disclosure; same for one college and one university. If it was a data file it would fit on a floppy disk with room to spare, and for those of a certain generation, not the 3 ½ inch floppy disk that became the save button onscreen, but rather the 5 ¼ inch floppy disk that has all but faded from memory.

Shine on you crazy diamond - Today

Fast forward 30 years, and a lot has changed. But not everything. The top paid job is the former head of Ontario Power Generation (one of the descendants of the now defunct Ontario Hydro), and the President & CEO of Sick Kids is still a top 10 role. However, the list now covers over 400,000 incumbents with over 600 executive assistants. The current file size eclipses the 1996 version; it would need to be stored on over a dozen floppy disks. Why? The reason is that the $100K threshold has not changed.

A salary of $100K in 1996 is roughly $185K in 2025 once inflation is factored in (an 85% increase). Assuming 2% inflation for the next few years (one can only hope), it means that in 2029 we will cross the $200K threshold. What happens if we apply this inflation adjusted threshold to today’s Sunshine List? If we look at jobs of at least $185K in 2025, we reduce the List from 400,000 to only 30,000. That’s a much more reasonable near 7-fold increase from 1996, rather than the current near 90-fold increase.

That said, Ontario’s population grew by roughly 1/3 from 1996 to 2021. So even after controlling for inflation, why has the list grown so much? Is it because of bigger government, or is there another reason? The biggest factor is that salaries tend to increase faster than inflation. As an example, inflation increased by an average of 2.08% in 2025 (despite what our grocery bills tell us). Conversely, numerous data sources indicate that salaries grew by closer to 3.5% in 2025. While not as high as 2022 or 2023, this figure is still higher compared to the 2010s where typical salary increases were 2.5%. Even if we make some simplifying assumptions about salary increases, between 1996 and 2025 the compounded total is almost 100%. Even with these conservative assumptions, salaries have outgrown inflation by 15% since the Sunshine List first appeared.

Copernicus commentary – Different ways of looking at the Sunshine List

Most discourse around the sunshine list concerns how much it grows every year. That overstates the gravity of the situation, as the annual revelation that it’s “bigger than it’s ever been” isn’t compelling. After all, the threshold is frozen, salaries don’t decrease, and Ontario’s population is increasing. Of course it’ll get bigger; always rising, like a balloon filled with helium.

An alternative analysis would be to compare how much the sunshine list has grown over the years and try to identify any previous or emerging trends in how growth has fluctuated, and observe the various zeniths and nadirs and what may have caused them.

We’ve analyzed four statistics across the most recent 28 sunshine lists, omitting the first two year-over-year changes to smooth out the data:

1. Year-over-year (YOY) change in number (#) of incumbents

2. YOY change in # of reporting organizations

3. YOY change in median salary

4. YOY change in average salary

Each statistic goes through noticeable peaks and valleys, and yet each ends with a different stellar conclusion.

YOY Change in # Incumbents

Years Covered	Trend	Avg. Increase	Range
1998 - 2009	Steady growth	23.6%	14% to 29%
2010 - 2014	Tempered growth	11.7%	10% to 14%
2015 - 2017	Stagnant growth	5.7%	4% to 7%
2018 - 2023	Back to normal?	14.8%	9% to 23%
2024	What?	25.6%	N/A
2025	Back to normal again?	7.2%	N/A

Figure 1: YOY Change in # Incumbents

Observation: the 25.6% increase in 2024 is the highest since 2008 and the second highest since 2003, while the 7.2% increase in 2025 is the smallest since 2017.

YOY Change in # Organizations

Years Covered	Trend	Avg. Increase	Range
1998 - 2010	Steady growth	9.7%	4% to 17%
2011 - 2023	Tempered growth	4.4%	0% to 8%
2024	What just happened?	-4.8%	N/A
2025	Back to normal part 2?	2.7%	N/A

Figure 2: YOY Change in # Organizations

Observation: the 4.8% decrease in 2024 is the first decrease since 1998, while the 2.7% increase is the smallest increase since 2019.

YOY Change in Median Salary

Years Covered	Trend	Avg. Increase	Range
1998 - 2019	What does pandemic mean?	0.1%	-1.4% to 1.7%
2020 - 2021	Where's my hand sanitizer?	-1.7%	-2.3% to -1.2%
2022 - 2023	Interest rates go supernova	1.8%	1.0% to 2.5%
2024	What the heck just happened?	8.7%	N/A
2025	Back down again	-2.5%	N/A

Figure 3: YOY Change in Median Salary

Observation: the 8.7% increase in 2024 is the largest increase by over 500 bp, while the 2.5% decrease in 2025 is the largest decrease.

YOY Change in Average Salary

Years Covered	Trend	Avg. Increase	Range
1998 - 2001	Finding our feet	2.0%	1.3% to 2.7%
2002 - 2019	The long plateau	-0.1%	-1% to 0.9%
2020 - 2021	The bad times	-1.4%	-1.7% to -1.2%
2022 - 2023	Getting back to normal	1.3%	1.0% to 1.6%
2024	What on Earth just happened?	4.4%	N/A
2025	Back to normal part 3?	1.3%	N/A

Figure 4: YOY Change in Average Salary

Observation: the 4.4% increase in 2024 is the largest increase by over 150 bp.

There are lots of interesting occurrences here, but can they be explained?

• Why did incumbent change slow so much in the mid 2010s? Perhaps due to the price of oil dropping, which slowed the Canadian economy and lowered federal tax revenue and thus provincial transfers. Possible but that’s a stretch. Hydro One being removed from the sunshine list as of 2015 is a factor, as they had roughly 4,000 people in 2014, which explains 2015 being the smallest increase ever (3.8%), but not 2016 and 2017 being almost as low (7.4% & 6.0%).

• Why did salaries decrease in 2020 and 2021? Bill 124 being passed in 2019 may have played a role. Another decent bet is that COVID put extreme short-term pressure on budgets and compensation, be it annual increases for non-union roles or pay for performance (P4P) for senior roles. A corona affecting sunshine; seems fitting.

• 2022 and 2023 corrected back to normal with regular increases, relaxed budget pressures and regular P4P for senior roles.

• On the other hand, 2024 is a gigantic outlier on all 4 fronts. Why so many more incumbents? Has the “normal distribution” of pay finally caught up with our $100K threshold? Why such noticeable compensation increases? Is it a knock-on effect from Bill 124 being struck down; but then why did so many organizations drop off? Turns out there was consolidation within the health sector, with many family health teams disappearing, and the LHINs being integrated into Ontario Health atHome.

Based on 2025 data, 2024 appears to be more of an outlier year than the new normal. Interestingly, 2025 appears to be a mix of both. In terms of incumbent YOY change and organization YOY change, 2025 reverts to typical numbers, albeit the smallest increases we’ve seen since before COVID. Regarding median salary, it shows the largest decrease ever, just edging out 2021 (-2.3%), which could reflect economic disruption and thus could be an outlier (hopefully). Average salary on the other hand seems to have reverted to expected levels, with 2025’s 1.3% increase matching the average increases in 2022 and 2023. We’ll need another spin around the sun to see what 2026 brings.

Sundown, you better take care – Itemized criticisms of the sunshine list and whether we agree (click the dropdowns for more details)

A. Improper conclusions can be drawn

Yes

B. It's useless

No

C. It adds excessive administrative burden to organizations in Ontario's BPS.

Maybe

D. $100K is no longer a useful threshold

I don't know

E. Why doesn't it better distinguish different types of compensation?

Can you repeat the question?

How to avoid sunburn – How to use the sunshine list properly

1. Be mindful of partial years.

   1. Someone going from $125K one year to $250K the next year doesn’t necessarily mean they received a 100% raise. More likely, they started on or about July 1^st last year and only received ½ their annualized compensation in the previous year.

   2. Conversely, someone going from $200K to $190K may not necessarily mean a decrease in pay. They may have left the organization in December, or they may have had unused vacation paid out the year prior, or they may have not received their full performance pay this year. We try to avoid drawing improper conclusions. Item A confirmed.

2. Verify the data if possible.

   1. Some organizations post executive contracts or collective agreements online; these data sources are much more useful than the PSSD while also accounting for partial years, part-time work, and other annual fluctuations.

3. Understand what the data is saying.

   1. The Salary column includes salary, pay for performance, and especially during the pandemic, unused vacation. It also includes per-diems and retainers.

   2. The Benefits column includes car allowances, employer-paid life insurance premiums and a litany of other items.

Sunset clause – Should we keep it around?

Pro keep – Keep on shinin’ in the BPS world

1. Removing a tool that is used to promote transparency may not be politically popular, and its removal may give potential bad actors some incentive to make unreasonable changes.

2. It’s an easy soundbite for the media and it generates some clicks.

3. It can be a useful analysis tool. Anyone can use the PSSD to see what their peers at other organizations are making. Most people in the orbit of compensation or consulting know that it can be used to help benchmark compensation and set salary ranges when other data sources fall short.

4. It still works. The PSSD gave visibility to massive salary increases within certain sectors.

Item B refuted

Pro remove – Blot out the Sun and fight in the shade

1)      It’s a lot of work for little gain. The average person sees very little use of it.

2)      It doesn’t stop bad actors, it only delays them.

3)      The outrage over its size and continued growth is mostly faux and its absence wouldn’t hurt.

4)      The personal toll of appearing on the list, if there is one, would disappear.

5)      Public sector HR workers likely save a bit of time each year. Item C addressed.

Believe in solar power – our suggested improvements

• New minimum salary. While the $100K threshold is simple and elegant, it is decades out-of-date. A new threshold of $150K or $200K would make more sense and would quiet debate about the sunshine list for at least another decade or two. There’s also precedent to this idea. Alberta’s public disclosure is indexed to Alberta’s annual CPI increase; its 2020 disclosure threshold was $113,400 while its 2025 threshold is $133,813. Adopting this change would also decrease the sunshine list’s overall size before it expands like a red giant to a point where it encompasses the entire Ontario public sector. Item D hypothesized.

• Better job titles. Most titles on the sunshine list are detailed. However, there are many cases where a title is “Director” or “Vice President”. We feel that titles should be more descriptive to give the public a better idea what these roles are doing. This goes along with the spirit of transparency of the list and helps users of the sunshine lists (like us) gain more understanding of the information presented.

• Stop paying attention to the rhetoric. Any article or tweet that uses the sunshine list’s release to broadly hurl slings and arrows at the government, or public servants, or whomever, is manufactured outrage. The Sunshine List is not necessarily proof of any of the above. Focus instead on real insights; YOY growth trends, etc.

• Regarding Item E, we feel that it could be useful to better distinguish the types of compensation received; whether it’s actual salary, P4P, unused vacation or other payments. Same goes for benefits; is it a car allowance, pension contributions, or something else? Practically speaking, it would fundamentally alter the list and make it more complex. We’re happy to let this suggestion slowly fade away (like a white dwarf).