Ontario is scheduled to implement two key employment law reforms aimed at improving transparency and safeguarding employee rights. Beginning 1 July 2025, employers will be required to provide new hires with key information before their first day of work. Additionally, starting 1 January 2026, all publicly advertised job postings must include expected compensation and disclose any use of artificial intelligence in the hiring process.
Background
Ontario has enacted a series of bills and regulations in recent years to amend employment-related laws such as the Ontario Employment Standards Act (the “ESA”) and is expected to continue proposing new legislation to enhance worker protections and address emerging workplace challenges under the “Working for Workers” series.
Key details
The most relevant changes for employers to note include the following:
Obligation to provide prescribed information to employees
Regulation 477/24 under the ESA introduces the new obligation for employers to provide specific information to employees.
From 1 July 2025, employers must provide the following information to all employees (except for assignment employees, being individuals employed by temporary help agencies) in writing before their first day of work, or as soon as reasonably possible thereafter:
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Employer’s legal name and any operating or business name
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Employer’s contact information, including address, telephone number, and one or more contact names
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General description of where the employee is initially anticipated to work and initial anticipated hours of work
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Employee’s starting wage or commission
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Pay period and pay day
This obligation will only apply to an employer which employs 25 or more employees on the employee’s first day of work.
Requirements for publicly advertised job postings
The new requirements for publicly advertised job postings have been introduced under the Working for Workers Four Act, 2024, the Working for Workers Five Act, 2024, and a subsequent Regulation 476/24. These changes are due to take effect on the same date of 1 January 2026.
External job postings that are advertised to the general public in any manner by an employer (or a person acting on their behalf) must meet certain new requirements from 1 January 2026. These requirements will only apply to employers who have 25 or more employees on the day the posting is listed.
The new requirements are as follows:
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Postings must disclose the expected compensation or compensation range. Compensation ranges must not exceed CAD 50,000. However, if the expected compensation or the upper limit of the compensation range exceeds CAD 200,000 annually, the employer is not required to disclose this information. This is intended to enhance Ontario’s current pay transparency and equity framework under the ESA and the Ontario Pay Equity Act (for more information, visit the Ontario government’s guide to equal pay for equal work here (opens a new window)).
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Postings are prohibited from including any requirements related to work experience in Canada, such as specifying local work experience as a condition for eligibility.
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Postings must disclose if the posting is for an existing vacancy.
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Postings must disclose if artificial intelligence is used to screen, assess or select applicants.
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Each applicant interviewed must be informed either in writing, in person, or via technology, whether a decision has been made within 45 days of such applicant’s interview (or their final interview, if the employer interviews the applicant more than once for the posting).
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Copies of every posting and associated application form must be retained for a period of three years after public access to the posting has been removed.
Employer action: ACT
Employers should review and prepare to update their policies, practices and procedures, employment contracts and collective agreements, as needed, to reflect the changes from their respective effective dates. In particular:
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Employers should consider revising their employment contract templates to comply with the new requirements to provide prescribed information to employees from 1 July 2025. However, employers must ensure that the information is provided to employees before their first day of work, or as soon as reasonably possible thereafter.
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Employers will need to ensure job postings comply with the new requirements from 1 January 2026, and that recordkeeping practices for recruitment records are updated accordingly.
Written in collaboration with:
Jessica Gobran
National Practice Leader, Disability Management (DM) Consulting
BFL CANADA Benefits (Lockton Global Partner)
[email protected] (opens a new window)
Further Information
O. Regulation 477/24 | ontario.ca (opens a new window)
Bill 149, Working for Workers Four Act, 2024 | Legislative Assembly of Ontario (opens a new window)
Bill 190, Working for Workers Five Act, 2024 | Legislative Assembly of Ontario (opens a new window)
