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We previously wrote about some of the legislative changes introduced under Ontario's Bill 149, or the Working for Workers Four Act, 2024, which amends key employment legislation including the Employment Standards Act, 2000 (the "ESA"). Below is a summary of key changes that came into effect this year, and important upcoming changes that will come into force as of January 1, 2026.
Changes Already in Effect as of July 1, 2025
Ontario employers with 25 or more employees must now ensure they provide the following information to new hires before their first day of work or as soon after as reasonably possible:
- legal name of the employer, and any other operating or business name if different from the legal name;
- the employer's contact information, including address, phone number, and one or more contact names;
- a general description of the employee's anticipated location and hours of work;
- the employee's starting hourly or other wage rate or commission, as applicable; and
- the pay period and pay day established by the employer in accordance with its obligation under the ESA.
Changes Coming into Force as of January 1, 2026
Key Job Posting and Pay Transparency Requirements: As of January 1, 2026, Ontario employers with 25 or more employees must include the following information in publicly advertised job postings:
- the expected compensation or range of compensation for the
advertised position, unless the compensation exceeds $200,000
annually or the compensation range exceeds $200,000 at the upper
limit;
- if a range of compensation is included in the job posting, the difference between the lower end and higher end of the range must not exceed $50,000 annually.
- a statement on whether or not the job posting relates to an existing vacancy;
- a statement on whether the employer uses artificial intelligence to screen, assess, or select job applicants.
As we previously reported, a publicly advertised job posting means an external job posting that an employer, or person acting on behalf of an employer, advertises to the general public in any manner.
Reminder: Under these changes, employers will be prohibited from including any requirements related to Canadian work experience in job postings.
Notification of Hiring Decision: Employers will be required to notify applicants about whether a hiring decision has been made for the advertised job within 45 days of the interview or, where more than one interview is conducted, within 45 days of the applicant's last interview.
Recordkeeping: Employers will be required to retain copies of each publicly advertised job posting and related application forms for a period of three years after the posting becomes unavailable to the public.
Takeaways
Employers should review their current policies and practices, including job postings, employment documents, and hiring practices, to ensure compliance with existing, and upcoming, new legal requirements. If you require assistance or guidance, please do not hesitate to reach out to a member of our employment team.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
