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Overview of Ontario’s Proposed ‘Working for Workers Four Act’

Friday February 16, 2024

In November 2023, the Ontario government proposed Bill 149, the ‘Working for Workers Four Act’, which if passed, would have direct consequences for pay transparency, AI disclosures, Canadian work experience requirements, WSIB benefits, and wage protections for restaurant and hospitality workers. This legislation builds on Bill 27, the Working for Workers Act which was passed in Ontario on December 2, 2021.

Electronic Monitoring: Bill 27, Working for Workers Act, 2021
As of October 11, 2022, Bill 27 requires employers in Ontario with more than 25 employees to have a written policy in place that discloses whether—and how—they electronically monitor their employees and management team during working hours.

Electronic monitoring may include:

  • tracking employee movements through access cards,
  • GPS devices on delivery vehicles,
  • tracking employee website visits, emails, and online chats, and
  • surveillance cameras (not primarily used for security).

The policy is required to include a description of how and in what circumstances the employer may monitor employees, the purpose for which information obtained through electronic monitoring may be used by the employer, and the date the policy was implemented, and when any revisions are made.

The Right to Disconnect: Bill 27, Working for Workers Act, 2021
Bill 27 also requires employers with 25 or more employees to develop and communicate a written policy for staff regarding disconnecting from work.

The Act defines “disconnecting from work” as “not engaging in work-related communications, including emails, telephone calls, video calls or the sending or reviewing of other messages, so as to be free from the performance of work.” The stated purpose of the legislation is to promote wellness and work-life balance for employees, and increase employee engagement.

While an employer may determine the specific contents of their own disconnecting from work policy, it should include:

  • when an employee is permitted to stop reading or replying to work-related emails and other correspondence,
  • when an employee is not expected to reply to such emails and correspondence or related phone calls,
  • expectations as to when an employee may be required to answer calls, respond to emails (i.e. after hours, extended from usual work hours, etc.), and
  • the date it was prepared and any subsequent updates.

Note: Employees need to be provided with a copy of the policy as well as any updates, and employers are expected to retain a copy of any past policies for three years after they have been updated.

Bill 149, Workers for Working Four Act, 2023
On November 14, 2023, the Ontario government introduced Bill 149, the Working for Workers Four Act, 2023. This update to the Working for Workers Act, 2021 is intended to strengthen Ontario employee entitlements and workers’ compensation benefits. If passed, employers will need to implement the following, and make policy changes where applicable:

  • Payment for trial shifts and trial work: ensuring that hospitality workers are paid for trial shifts, work performed during a trial period, training, etc.
  • Pay deductions due to customer theft: prohibiting deductions from an employee’s wages to cover loss caused by customer theft
  • Gratuities and tips (enhanced transparency and fairness in the distribution of employee tips): pay employee tips and gratuities by way of cash, a cheque payable to the employee, direct deposit (directly into employee’s personal financial account), or any other prescribed payment method. Additionally, tip-sharing or the pooling of tips must be set out in a policy, communicated to employees in advance, and posted in a conspicuous place.
  • Recruitment practices: improve an employee’s decision-making in the job market by introducing pay transparency initiatives:
      • include expected salary range or hourly rate in job postings
      • disclose in a job posting if using AI to screen, assess or select applicants
      • job postings prohibited from stating “Canadian experience required”
      • copies of all publicly advertised job postings must be retained for 3 years after being removed from public view
  • Vacation pay: where there may be alternative vacation pay arrangements, an agreement specifying the terms must be in place with the employee
  • Injured employees: amendments may be made to the Workplace Safety and Insurance Act, 1997 (WSIB) to permit indexing increases to WSIB benefits above the annual rate of inflation
  • New benefits for firefighters and fire investigators: esophageal cancer contracted by firefighters with at least 15 years of service, including full-time, part-time, fire investigators or volunteer firefighters, would be presumed as an occupational disease (applies to diseases diagnosed on or after January 1, 1960)
  • Licensing requirements for recruiters: “vulnerable and temporary foreign workers” will be protected from instances of “illegally paying people below the minimum wage and denying other basic employment rights to gain an unfair competitive advantage over law-abiding agencies by undercutting rates”

S+C Partners is committed to helping you.
It is important to stay up to date on existing, new, and proposed employment policies, regardless of the size of your business or the industry you are in. Our in-house team of experts includes a Certified Human Resource Professional and Leader (CHRP/CHRL) who specializes in the development of organizational practices and employee relations, talent acquisition, health and safety, training and performance management. Please call us at 905-821-9215 or email us at if you have any questions or require any assistance regarding the proposed ‘Working for Workers Four Act’.


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