It's a good legal question.
I can tell you that considering the act came into force on April 15, and the person has 60 days to submit a complaint to the commissioner to investigate it and possibly have that case come to the tribunal, technically speaking, it is 60 days starting on April 15.
I would assume--avec réserve, of course--that if the facts happened before the coming into force of the act...but the moment his right was created to submit a complaint, it was after the coming into force of the act. Technically it may be possible that we have to...or not us, but the commissioner will deal with the case and may refer it to us.
That question may be interesting to ask the commissioner as well.