Regardless of whether a complaint is made, the Act requires all employers to whom it applies to achieve and maintain pay equity. The Tribunal has confirmed that Review Officers may investigate employers and issue orders even if no complaint has been made. If an employer is reviewed proactively by the Office, the employer may be required to demonstrate that there were no pay equity gaps identified as a result of comparisons between female and male job classes of equal or comparable value; or if there were gaps that they were closed, i.e. female job classes are being paid at least the same as male job classes of equal or comparable value. If the investigation reveals that the employer did not meet its obligations under the Act, the employer would be required to do pay equity retroactively, and to pay any necessary retroactive adjustments with interest.