Deadlines approaching for new rules meant to better protect applicants
A major shift is coming to Ontario's hiring practices and employers need to be ready for it. Starting Jan. 1, 2026, new pay transparency and artificial intelligence (AI) disclosure requirements will be in force in the province under the Working for Workers Four and Five Acts. For HR professionals and employers, this is much more than compliance tweaks, as it requires a revamp of job postings, recruitment processes, and candidate communication practices. Failing to appropriately prepare for these changes could lead not only to fines, but to reputational risk in a competitive talent market.
The steps taken by the Ontario government are in line with a global move toward encouraging wage transparency and promoting fair and inclusive hiring processes. Wage transparency is intended to reduce disparities in employment based on gender, race and other factors. AI disclosure reforms seek to address growing concerns about the role of automated tools in recruitment and hiring processes.
The goal is not just to protect applicants, but to drive better business practices that build trust in the hiring process, increase the quality of applicants, and lead to long-term retention. By understanding and embracing these changes, employers will not only comply with the law but will strengthen their talent strategy.
Beginning on July 1, 2025, employers with 25 or more employees will be required to provide the following employment information in writing to new employees prior to their start date:
The legal name of the employer, contact information, anticipated work location, starting wage, pay period and pay day, and description of anticipated initial hours of work.
Beginning Jan. 1, 2026, employers with 25 or more employees will be required to do the following:
Post salary information - all job postings must include the expected salary or the salary range (the range cannot exceed $50,000, unless the annual compensation is over $200,000).
Report if AI is used - employers must disclose if they use AI to select, screen, or assess applicants. This includes disclosing the use of AI scanners or other AI-driven tools in hiring processes.
Cannot require “Canadian experience” - job posting may not require applicants to have Canadian work experience unless specifically exempted under the law.
Confirm status of role - job postings must state whether the role is an open vacancy.
Post-interview communication - within 45 days, employers must notify those interviewed for a role about the final hiring decision.
These changes are not minor administrative details - they require a shift in operations and culture. Employers should consider implementing the following practices sooner rather than later:
Update employment agreements - revise template employment agreements (by July 1, 2025) to incorporate pre-employment information.
Review job posting practices - revise template postings to accommodate mandatory salary and AI disclosures.
Review AI practices - if you use AI-driven tools in recruitment, document and disclose their use, and review the processes of these tools to avoid any hidden biases.
Review and define salary ranges to ensure they are defensible - wide or arbitrary compensation ranges will not be acceptable. HR teams must create realistic and justifiable ranges and be prepared to discuss the range with candidates.
Train hiring managers - Educate staff on these new obligations, particularly regarding the requirement to communicate hiring decisions to all interviewed candidates within 45 days of the interview.
Policy update - Update all relevant policies to comply with new standards.
While the Working for Workers Acts Four and Five add new requirements for employers, they also have the potential to present an opportunity. Employers who welcome this move toward transparency in hiring practices will strengthen their brand, attract a diverse talent pool, and increase trust with candidates. Smart HR teams will view these changes not as legal requirements, but as a chance to modernize recruitment and foster stronger more inclusive and dynamic organizations.
Lindy Herrington is an employment lawyer at Turnpenney Milne in Toronto.
