Ontario’s pay transparency era officially begins on January 1, 2026. Under the Working for Workers Four Act (Bill 149), employers with 25 or more employees must meet new requirements for publicly advertised job postings, including mandatory salary range disclosure.
If your organization hasn’t updated its hiring practices yet, the clock is ticking. Here’s what you need to know to stay compliant.
What Counts as a Publicly Advertised Job Posting?
Under Ontario Regulation 476/24, the new rules apply to external job postings advertised to the general public through any channel, whether that’s job boards, social media, your company website, or recruitment platforms.
However, certain postings are exempt:
- General recruitment campaigns that don’t advertise a specific position
- Generic “help wanted” signs without specific role details
- Internal postings restricted to current employees
- Positions where work will be performed entirely outside Ontario
Key Requirements Taking Effect January 1, 2026
Salary Range Disclosure
Employers must include expected compensation or a compensation range in every publicly advertised job posting. If you provide a range, it cannot exceed $50,000. For example, a range of $80,000 to $130,000 would be compliant, but $80,000 to $140,000 would not.
There is one notable exception: positions with expected annual compensation exceeding $200,000 are exempt from this requirement.
No Canadian Experience Requirements
Employers cannot include “Canadian experience” as a requirement in job postings or application forms. This provision aims to reduce barriers for newcomers and internationally trained professionals entering the Ontario workforce.
AI Disclosure Statements
If your organization uses artificial intelligence to screen, assess, or select candidates, you must disclose this in the job posting. The legislation defines AI broadly as any machine-based system that generates outputs such as predictions, recommendations, or decisions based on input data.
This requirement reflects growing regulatory attention to algorithmic hiring tools and their potential impact on equitable candidate evaluation.
Existing Vacancy Disclosure
Job postings must indicate whether the position represents an existing vacancy. This transparency measure helps candidates understand if they’re applying for an immediate opening or a potential future role.
Post-Interview Communication
Employers must inform interviewed candidates whether a hiring decision has been made within 45 days of their last interview. This communication can be delivered in person, in writing, or through technology.
Record Retention
Organizations must retain copies of all publicly advertised job postings and associated application forms for three years after the posting is removed from public access.
Employment Information Requirements Already in Effect
As of July 1, 2025, under amendments to the Employment Standards Act, 2000, Ontario employers with 25 or more employees must provide new hires with specific written information before their first day of work, or as soon as reasonably possible thereafter. This information includes:
- The employer’s legal name and any operating or business names
- Employer contact information, including address, telephone number, and contact names
- A general description of where the employee will initially perform work
- Starting wage rate or commission structure
- Pay period and pay day
- A general description of anticipated initial hours of work
If your organization hasn’t yet updated its onboarding documentation to include these details, compliance should be an immediate priority.
Which Employers Are Affected?
The 25-employee threshold applies to both sets of requirements. For job posting rules, the count is based on the day the posting goes live. For employment information requirements, it’s based on the new hire’s first day of work.
Temporary help agencies should note that assignment employees are exempt from the employment information provisions.
Steps to Prepare for Compliance
- Audit your current job posting templates. Review every template your organization uses to ensure fields exist for salary ranges, AI disclosure, and vacancy status.
- Update your applicant tracking system. Configure your ATS to require compensation information and generate compliant postings. Build in workflows to track 45-day post-interview communication deadlines.
- Train your hiring managers. Ensure everyone involved in recruitment understands the new requirements, particularly around what constitutes a compliant salary range and when AI disclosure is triggered.
- Review your onboarding documents. If you haven’t already addressed the July 2025 employment information requirements, update your offer letters and onboarding checklists now.
- Establish record retention processes. Implement systems to archive job postings and application forms for the required three-year period.
The Bigger Picture: Pay Transparency Across Canada
Ontario joins a growing number of Canadian provinces implementing pay transparency legislation. British Columbia, Prince Edward Island, already require salary disclosure in job postings, and Newfoundland and Labrador has passed legislation with pay transparency provisions that have not yet come into force. Nova Scotia has also tabled pay transparency legislation, and other provinces are considering their own frameworks.
For organizations operating across multiple provinces, this patchwork of requirements underscores the need for a centralized, adaptable approach to compensation transparency. Building flexibility into your job posting processes now will position your organization to respond efficiently as additional jurisdictions introduce their own rules.
How Diversio Can Help
Several of Ontario’s new requirements intersect directly with inclusive hiring practices. If your organization is reviewing job postings for compliance, it’s an opportune moment to address bias and inclusion simultaneously.
Inclusive Recruitment with Lumi
Lumi, Diversio’s AI-powered recruitment assistant, helps organizations create job postings that are both compliant and inclusive. Unlike generic AI writing tools, Lumi is purpose-built for recruitment and analyzes job descriptions for biased language, including phrases like “Canadian experience” that Ontario’s new rules explicitly prohibit.
If you use Lumi or any AI tool in your hiring process, Ontario’s disclosure requirement applies. The difference is that Lumi is designed to reduce bias in candidate evaluation rather than introduce it, making the required disclosure a feature rather than a liability.
Lumi can help your team:
- Identify and remove exclusionary language from job postings
- Ensure postings meet inclusive hiring best practices
- Optimize job ads to reach diverse talent pools
- Maintain consistency across hiring managers and departments
Employment Equity Reporting Support
Pay transparency is just one piece of a broader compliance landscape. Organizations navigating Ontario’s new requirements often face overlapping obligations under federal and provincial employment equity legislation.
Diversio’s Employment Equity Support services help organizations prepare for 2026 and beyond with:
- Workforce data collection using our Diversity Meter service to capture demographic data and surface inclusion issues
- WEIMS reporting support to create properly coded files for upload, including preliminary workforce analysis to identify errors before submission
- Employment Systems Review project management to ensure all aspects of your employment practices are reviewed and documented
- Compliance reporting aligned with Bill C-25, EEO-1, and other regulatory frameworks
Whether you’re a federally regulated employer preparing for Employment Equity Act reporting or a provincially regulated organization tracking diversity metrics for stakeholders, our consulting team can guide you through the process.
Beyond recruitment, Diversio’s Core platform measures inclusion across your workforce, helping you understand whether your hiring practices translate into equitable employee experiences.
Ready to make compliance work harder for your organization? Explore our Employment Equity support, or contact us to discuss your 2026 compliance goals.
