Ontario Pay Transparency Rules: 2026 Guide

Ontario's job posting rules start 1 January 2026 for employers with 25 or more staff: pay ranges, AI screening disclosure and record keeping. What to change and where.

What Changes on 1 January 2026

From 1 January 2026, an Ontario employer with 25 or more employees must include pay information in every publicly advertised job posting, disclose whether artificial intelligence is used to screen applicants, and keep copies of its postings. The rules come from the Working for Workers legislation, which amends the Employment Standards Act, 2000.

The important point for anyone running a careers page is that this is not only a wording change. Three of the requirements are about information your posting system has to hold, produce or retain, which is why so many employers find the problem sits in software rather than in the copy.

RequirementWhat the posting must do
Pay informationGive a specific wage or salary, or a range
Range widthKeep the range within $50,000, with an exception at the top end
Other compensationDisclose bonuses, commissions and other pay
AI screeningSay whether AI is used to screen, assess or select applicants
Existing vacancySay whether the posting is for a real, current opening
Canadian experienceMust not require Canadian work experience
RecordsKeep the posting, and any associated application form, on file

This article explains each one in plain terms and then looks at the part nobody enjoys: making your existing careers page, job board feeds and applicant tracking system actually do it. It is general information, not legal advice. Confirm your own obligations with an employment lawyer or with the Ontario Ministry of Labour before you rely on anything here.

Who It Applies To

The threshold is 25 or more employees. Below that you are outside these particular job posting rules, though pay transparency is becoming normal in Canadian hiring regardless of what the law requires of you.

Two things catch employers out. The first is that the count is of employees, not of full-time equivalents, so a business running on part-time staff can cross the line without feeling any bigger. The second is that the rules attach to publicly advertised postings. An internal-only vacancy sits in a different position from the same role advertised on your website or a job board, so the two paths through your hiring process may not need the same treatment.

If you operate in more than one province, assume the rules differ and plan for that. British Columbia already requires pay ranges in publicly advertised postings and separately requires annual pay transparency reports, which widen to employers with 50 or more BC employees on 1 November 2026. We cover that in BC pay transparency reporting.

The Pay Range Rule and the $50,000 Cap

You must give either a specific figure or a range, and the range cannot be wider than $50,000. So $60,000 to $110,000 is allowed. $60,000 to $140,000 is not. There is an exception where the top of the range is above $200,000 a year, or total compensation reaches at least $200,000.

The cap exists because ranges in other jurisdictions became so wide that they told candidates nothing. It has a practical consequence: if your pay bands are wider than $50,000, you cannot simply publish the band. You have to decide what to advertise for each posting, which is a compensation decision rather than a recruiting one.

Where this usually breaks

  • Bands held in a spreadsheet that nobody owns, so each hiring manager invents a range
  • A job board integration that posts a title and description but has no pay fields to send
  • Roles that span two bands, where the honest range is wider than the law allows
  • Bonus and commission plans that live in a separate document from the salary band
  • Postings syndicated to several boards, where one feed carries the pay and the others do not

The last one matters more than it sounds. If your posting goes to your own site, a job board and an aggregator, every public copy is a public posting. One feed that drops the pay field is a non-compliant posting with your name on it.

Disclosing AI Screening

If you use artificial intelligence to screen, assess or select applicants, the posting has to say so. The disclosure itself is a sentence. Working out whether it applies to you is the harder part.

Plenty of employers use AI screening without having decided to. It arrives as a feature inside an applicant tracking system: resume ranking, a match score, knockout question scoring, an interview scheduler that shortlists, a chatbot that qualifies candidates before a human sees them. If a vendor feature orders or filters your applicants, that is worth a direct question to the vendor in writing.

  • Ask each hiring tool vendor, in writing, whether their product screens, assesses or selects applicants
  • Keep the answer, because the posting disclosure needs to stay accurate as the product changes
  • Decide who updates the disclosure when you switch tools or turn a feature on
  • Treat an added match-score feature as a change that touches your postings, not just a release note

There is a reason to be careful rather than casual here. A vendor can add a ranking feature in a routine update, and your postings then describe a process you no longer run.

Record Keeping, and Why It Is a Software Problem

You have to keep copies of your publicly advertised postings and any associated application forms. This is the requirement that most often has no owner, because the posting usually lives wherever it was last edited.

A posting on a modern careers page is generated from a record in a database and rendered on request. Take the record away and the posting is gone. Nobody kept the version that was public in March, with March's pay range and March's AI disclosure, because the page always showed the current one.

The fix is not complicated, but somebody has to build it: store a snapshot of each posting as published, with the date it went live, the date it came down, and the exact pay and disclosure text it carried. Then an enquiry about a posting from eight months ago is a lookup instead of an archaeology project.

ApproachWorks whenRisk
Your ATS retains versionsThe vendor keeps published snapshots and you can export themMany retain the current record only
Snapshot on publishPostings are published through one system you controlNeeds building once, then it is automatic
Manual PDF of each postingYou post a handful of roles a yearForgotten the first busy month
Nothing in particularNeverYou cannot show what a posting said

What This Asks of Your Systems

Most of the work lands in four places: the careers page, the applicant tracking system, any job board feeds, and wherever compensation bands are kept. The order matters, because fixing the careers page while the feeds still strip the pay field solves the visible half of the problem and leaves the rest.

  • Careers page: pay fields that cannot be left blank, an AI disclosure field, and a vacancy flag
  • Applicant tracking system: the same fields, plus retention of what was published and when
  • Job board and aggregator feeds: every destination carries pay and disclosure, or it is not used
  • Compensation data: one source for bands, with an owner, so ranges are not invented per posting
  • Application forms: no Canadian experience requirement anywhere in the form or its questions

If your careers page is a WordPress site with a jobs plugin, the question is whether the plugin has pay and disclosure fields and whether its feed includes them. If your postings come out of an applicant tracking system, the question is what the vendor retains and what it will export. Where a packaged tool cannot do it, that gap is the usual reason to build. We cover the decision in applicant tracking systems in Canada and the wider data problem in payroll software in Canada.

A note on sequencing. The pay range rule is the one candidates will notice on 2 January. The record keeping rule is the one that is expensive to fix retroactively, because you cannot go back and keep something you did not keep. If you only have time for one before the deadline, make the postings compliant; then put snapshotting in place immediately after, not next year.

A Checklist to Work Through Before January

  1. Count your employees and confirm whether you are at or above 25
  2. List every place a job of yours appears publicly, including boards and aggregators you forgot about
  3. Check each one can carry a pay figure or range, and that the field is actually sent
  4. Review your bands: any wider than $50,000 needs a decision about what gets advertised
  5. Write down your bonus and commission disclosure wording once, so it is consistent
  6. Ask every hiring tool vendor in writing whether their product screens or ranks applicants
  7. Add the AI disclosure, and name the person who keeps it accurate
  8. Remove any Canadian work experience requirement from postings and application forms
  9. Decide how a published posting is retained, and test that you can retrieve last month's
  10. Have an employment lawyer review your template posting before you publish it

If step three or step nine turns out to be a wall, that is usually a software limitation rather than a policy one. We build careers pages, posting workflows and the integrations between an applicant tracking system and the places your jobs appear. Tell us what you are working with and we will tell you whether it needs a change or a rebuild, in writing, before any work starts.

Frequently asked questions

When do Ontario's new job posting rules start?

1 January 2026, for employers with 25 or more employees. Confirm your own position with the Ontario Ministry of Labour or an employment lawyer, because this article is general information rather than legal advice.

How wide can a salary range be in an Ontario job posting?

The range cannot be wider than $50,000, so $60,000 to $110,000 is allowed. There is an exception where the top of the range is above $200,000 a year or total compensation is at least $200,000.

Do we have to say we use AI in hiring?

If you use artificial intelligence to screen, assess or select applicants, the posting must disclose it. Many employers have this through an applicant tracking system feature rather than a deliberate choice, so ask each vendor in writing what their product does.

Does this apply to internal job postings?

The requirements attach to publicly advertised postings, so an internal-only vacancy sits in a different position from the same role advertised publicly. Check the specifics for your situation, because how you advertise matters more than what you call it.

What records do we need to keep?

Copies of publicly advertised postings and any associated application forms. The practical difficulty is that most careers pages render the current version of a posting and keep no history, so retaining what was published usually needs to be built.