The clock starts once seven straight days pass with no work and no pay — and paper and electronic ROEs then run on two different deadlines from there.
Short answer
The federal Employment Insurance Regulations trigger the obligation once an employee has “seven or more consecutive days” with no work performed and no earnings payable — that's the “interruption of earnings.” A paper ROE must reach the employee within five days after that point (or after the employer becomes aware of it); an electronic ROE is due to Service Canada by whichever comes first — five days after the relevant pay period ends, or fifteen days after the interruption began, for employers with 13 or fewer pay periods a year.
The trigger itself comes from section 14 of the Employment Insurance Regulations: “an interruption of earnings occurs where, following a period of employment with an employer, an insured person is laid off or separated from that employment and has a period of seven or more consecutive days during which no work is performed for that employer and in respect of which no earnings … are payable or allocated.” It's the seven-day gap that legally starts the clock, not the layoff notice itself — a worker recalled on day four never triggers the obligation at all.
Section 19 sets the actual deadlines, and they differ by format. For a paper ROE, “the employee's copy shall be delivered to the insured person not later than five days after” whichever is later of the interruption's first day or the point the employer becomes aware of it. For the electronic version, the deadline is whichever comes first of “five days after the end of the pay period” containing the interruption's first day, or “15 days after the first day of the interruption” — that second option only applies to employers running 13 or fewer pay periods a year.
Worked through: a worker's last paid shift is June 1. No further shifts and no pay follow, so the first day with no work at all is June 2 — the “first day of the interruption.” Seven consecutive days without work or pay (June 2 through June 8) confirm the interruption on June 8. The paper ROE is then due to the worker within five days of that point — by June 13. The electronic ROE is due to Service Canada by the earlier of five days after the pay period containing June 2 ends, or fifteen days after June 2 itself — June 17 at the latest, for an employer on 13 or fewer pay periods a year.
The regulation also covers the practical failure cases: where an employer genuinely cannot deliver within the window, section 19 allows mailing it or retaining it pending a request, and separately addresses what happens if records are destroyed or an employer simply never provides one — the claimant can supply evidence, or Service Canada can reconstruct hours and earnings from other payroll records. None of that removes the original deadline; it's the fallback when it's missed, not a substitute for hitting it.
Whether the person being laid off was on payroll as an employee in the first place is worth confirming before any of this — ROE obligations follow insurable employment, and a genuinely misclassified sub raises that question first: how to tell if a worker is really an employee. And if the layoff follows a period where the crew was regularly over 44 hours a week, back-check that the final pay reflects it — see how overtime is actually calculated.
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