As 2026 approaches, Ontario employers must prepare for continual changes to the Employment Standards Act, 2000 (ESA). Bill 149 and Bill 190 have already been enacted, and the Working for Workers Seven Act (Bill 30) is expected to take effect in a two phase roll out of requirements affecting job postings and recording which has already come into effect.
What is the Timeline?
To represent Ontario’s latest effort in fostering transparency and equity in workplaces, the ESA requirements will apply to employers with 25 or more employees.
- As of July 1, 2025 employment information requirements for new hires are in effect. They do not apply to assignment workers, and no update to the system generated notification is required.
- On January 1, 2026, the proposed public job postings requirements will be placed into effect.
Employment Information for New Hires (Came into Effect July 1, 2025)
As of July 1, 2025, employers are required to provide new employees with specific information, in writing, before their first day of employment, or as soon as possible after, should providing an employment agreement before their first day not be possible.
Exemptions
These employer information requirements do not apply to organizations with fewer than 25 employees. Additionally, assignment employees, those hired by temporary help agencies for short-term or client-specific roles, are exempt from these requirements.
Required Information
Employers are now required to provide the following information to new hires:
- Legal Employer Name and any associated operating business names
- Contact Information, including business address, telephone number, and relevant contact persons
- General Description of the Workplace
- Compensation Details, such as starting salary/hourly wage, other applicable wage rates, or commission structure, etc.
- Pay Schedule, including the pay period and designated pay day
- Work Hours Overview, outlining the employees’ initially anticipated hours of work.
It is highly recommended this information be provided to employees in the form of an employment agreement, along with other relevant employment terms and conditions.
Job Posting Requirements (Effective January 1, 2026)
Ontario’s Working for Workers Four Act, 2024 and Working for Workers Five Act, 2024 included comprehensive regulations surrounding public job postings. The latest proposed Working for Works Seven Act, 2025, further clarifies the details of these employer obligations.
Defining a Publicly Advertised Job Posting
A publicly advertised job posting refers to any external job opportunity that an employer, or someone acting on their behalf, shares with the general public through any form of communication or media.
Notable exemptions include:
-
- Help wanted signs that do not specify any particular job position
- Internal-only postings restricted to current employees
- General recruitment campaigns that do not advertise a specific role
- Job postings for positions with specific work conditions outside of Ontario.
Updates to Job Posting Requirements
Pay Transparency in Job Postings
As of January 1, 2026, employers will be required to include a salary or compensation range in all publicly advertised job postings. Compensation includes what the ESA outlines as “wages”. For most roles, this range cannot exceed $50,000 unless the top end surpasses $200,000 annually. This measure aims to reduce pay disparities and promote equitable hiring practices.
Canadian Experience Restrictions
Employers are prohibited from requiring “Canadian experience” as a qualification for roles in job postings or application forms. This allows for newcomers and internationally trained professionals, living in Canada yet lacking Canadian work history, an equitable opportunity for the job.
Disclosure of Vacancy Status
Job postings will need to indicate whether the position is for an existing vacancy or a newly created role, providing clarity for applicants and managing expectations.
Post-Interviewed Communication
Interviewed candidates must be notified of the hiring decision within 45 days of the interview, whether hired for the role or not.
Artificial Intelligence (AI) Disclosure
The use of AI in the recruitment process at any stage, including screening, assessing, or selecting applicants, must be disclosed and outlined in the job posting.
Next Steps
These changes reflect a significant shift in Ontario’s Employer Requirements. Businesses with 25 or more employees should begin preparing by:
- Update job posting templates to include salary ranges, AI usage disclosures, and vacancy status
- Update recruitment processes and onboarding materials to accommodate new ESA disclosure requirements
- Adapt workplace policies to reflect changes in definitions of the workplace (including remote work), hygiene standards, sick leave, and harassment (which now includes virtual conduct)
- Train managers and recruiters on the new legal obligations and best practices for equitable hiring.
The updates to Ontario’s Employment Standards Act (ESA) reflect a broader shift toward increased transparency and enhanced protections for workers.By planning, employers and their leaders can smoothly implement these changes while strengthening their approach to recruitment and employee engagement.
At S+C Partners, we’re here to support you and your business.
Please call us at 905-821-9215 or email us at hr@scpllp.com if you have any questions concerning these updates or require HR advisory or support. Our HR Director, Dinah Sheffrin can help you navigate these employment changes.
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