Ontario's New Hiring Rules Start January 2026: 7 Compliance Steps Every Employer Must Take Now

Ontario employers with 25 or more employees have less than three months to prepare for the most comprehensive hiring compliance overhaul in years. Starting January 1, 2026, new regulations will fundamentally change how you post jobs, screen candidates, and manage your recruitment process.

These aren't minor tweaks: they're significant operational changes designed to increase transparency, reduce barriers for job seekers, and modernize Ontario's employment landscape. The question isn't whether these changes will impact your business, but whether you'll be ready when they take effect.

Here are the seven critical compliance steps you need to implement now.

1. Revamp All Job Postings with Mandatory Pay Transparency

Every job posting must now include salary ranges or pay limits. This isn't optional: it's a legal requirement that applies to all positions, with specific posting rules you need to understand.

Key Requirements:

• Maximum salary range you can post is $50,000 (e.g., if a role pays $70,000-$90,000, post it as "$70,000+")

• Positions paying over $200,000 annually are exempt from range disclosure

• All active job postings must comply immediately upon implementation

Action Steps:

• Audit every job posting template in your system

• Train hiring managers on proper salary range formatting

• Update automated job board integrations to include pay information

• Prepare internal guidelines for determining appropriate pay ranges to post

This change will require coordination across HR, finance, and hiring managers to ensure consistency and legal compliance while protecting competitive salary information.

2. Implement AI Disclosure Requirements Across All Platforms

If your organization uses any artificial intelligence tools in the hiring process, this must be clearly disclosed in every job posting. This requirement is broader than most employers realize and covers various automation tools commonly used in recruitment.

What Requires Disclosure:

• Applicant tracking systems with AI-powered resume screening

• Automated candidate ranking or scoring systems

• Chatbots handling initial candidate interactions

• AI-driven assessment tools or video interview platforms

• Machine learning algorithms that filter or evaluate applications

Implementation Strategy:

• Create standardized AI disclosure language for all job postings

• Inventory all recruitment technology to identify AI components

• Develop clear, candidate-friendly explanations of how AI is used

• Train recruitment staff on when and how to communicate AI usage

The goal is transparency, not elimination of AI tools. Candidates have the right to know when automated systems are evaluating their applications.

3. Establish Clear Position Classification Standards

Every job posting must specify whether the position is "new" or an "existing vacancy." This seemingly simple requirement needs systematic implementation across your entire recruitment process.

Classification Guidelines:

• New Position: Role created due to business growth, new department, or additional capacity needs

• Existing Vacancy: Replacing someone who left, covering maternity leave, or filling a previously occupied role

Operational Changes Needed:

• Update all job posting templates to include position type

• Train hiring managers to properly categorize openings

• Create approval workflows that capture this information early in the posting process

• Ensure consistency across all job boards and recruitment platforms

This classification helps job seekers understand market dynamics and career opportunities within your organization.

4. Eliminate Canadian Experience Requirements Immediately

This change removes a significant barrier for newcomers to Canada and applies to all job descriptions, postings, and recruitment communications. The prohibition is comprehensive and requires immediate attention.

Compliance Actions:

• Remove any mention of "Canadian work experience" from all job descriptions

• Eliminate requirements for familiarity with "Canadian business practices" unless genuinely essential

• Focus requirements on specific skills, qualifications, and relevant experience instead

• Update saved templates and automated posting systems

Alternative Qualification Approaches:

• Specify required technical skills and competencies

• Focus on industry experience rather than geographic location

• Emphasize language proficiency where legitimately required

• Highlight transferable skills and international experience value

This change reflects Ontario's commitment to leveraging diverse talent and reducing systemic barriers in employment.

5. Establish Comprehensive Record-Keeping Systems

Employers must maintain detailed records of all job postings and hiring decisions for three years. This goes far beyond simply saving job descriptions: you need systematic documentation of your entire recruitment process.

Required Documentation:

• Original job postings with timestamps and platform information

• All candidate applications and resumes received

• Interview notes and evaluation criteria

• Hiring decision rationales and timelines

• Communication records with all candidates

System Implementation:

• Upgrade your applicant tracking system to capture required data

• Train interviewers on proper documentation standards

• Create standardized templates for interview notes and decision records

• Establish secure storage systems for long-term record retention

These records protect your organization during potential disputes and demonstrate compliance with hiring regulations.

6. Create Robust Candidate Communication Timelines

Perhaps the most operationally challenging requirement: you must inform all interviewed candidates whether a hiring decision has been made within 45 days of their interview. This applies to any formal interview process, not preliminary screening calls.

Timeline Management:

• Track all interview dates for every candidate

• Set up automated reminders at 30 and 40-day marks

• Prepare standard communication templates for various scenarios

• Train hiring managers on timeline compliance responsibilities

Communication Requirements:

• Notify candidates of hiring decisions within 45 days

• Provide clear timelines if decisions are still pending

• Maintain professional communication throughout the process

• Document all candidate communications for record-keeping

This requirement significantly impacts recruitment workflow and requires dedicated tracking systems to ensure no candidate communication deadlines are missed.

7. Standardize New Hire Information Packages

Every new employee must receive comprehensive employer information in writing. Some of these requirements took effect in July 2025, so immediate attention is required if you haven't addressed them yet.

Required Information:

• Complete legal and operating business names

• Full contact information including physical addresses

• Expected work hours and location details

• Starting compensation breakdown and pay period information

• Benefits information and eligibility criteria

Implementation Priority:

• Create standardized new hire information packages

• Update onboarding processes to include all required disclosures

• Train HR staff on information delivery requirements

• Establish systems to track information delivery and receipt

This requirement ensures transparency from the first day of employment and sets clear expectations for the working relationship.

Understanding Exemptions and Scope

Not all organizations and postings fall under these requirements. The regulations don't apply to:

• Employers with fewer than 25 employees

• Internal job postings for existing employees

• General recruitment advertisements without specific position details

• Positions located outside Ontario

• Temporary staffing assignments through agencies

However, if your organization meets the 25-employee threshold, virtually all external job postings will require compliance.

Implementation Timeline and Priorities

With January 1, 2026 approaching rapidly, prioritize these actions:

Immediate Actions (October-November 2025):

• Update job posting templates with pay transparency and AI disclosure requirements

• Audit and remove Canadian experience requirements

• Implement record-keeping system upgrades

December 2025 Focus:

• Train all hiring managers and HR staff on new requirements

• Test candidate communication tracking systems

• Finalize new hire information package templates

The organizations that proactively implement these changes will not only ensure compliance but likely improve their candidate experience and employer brand. While the operational adjustments may seem daunting, they represent Ontario's commitment to fairer, more transparent hiring practices that benefit both employers and job seekers.

For specific guidance on implementing these changes within your organization's unique structure, consulting with employment law professionals can ensure comprehensive compliance and smooth operational transitions.