Preparing For Ontario’s New Pay Transparency Legislation

What employers need to know and what is needed to prepare for Pay Transparency.

TAP - Pay Transparency in Ontario

Ontario's new pay transparency legislation requires employers with 25 or more employees to include a salary or wage range in all public job postings, effective January 1, 2026. The changes, introduced through the Working for Workers Four Act, 2024 (Bill 149), are intended to address wage gaps and promote a more transparent hiring process. 

Key provisions for employers (effective January 1, 2026)

For employers with 25 or more employees, the following requirements apply to publicly advertised job postings:

• Compensation disclosure: Postings must include the expected compensation or a pay range.

  • The range cannot exceed $50,000, e.g., "$100,000 to $150,000" is acceptable, but "$100,000 to $200,000" is not.

  • The disclosure is not required for roles where the annual compensation is expected to exceed $200,000.

• AI disclosure: If artificial intelligence is used to screen, assess, or select applicants, this must be stated in the posting.

• No "Canadian experience" requirements: Employers are prohibited from including requirements for "Canadian experience" in job postings or application forms.

• Vacancy disclosure: Postings must indicate whether the position is for an existing vacancy.

• Post-interview notification: Employers must notify interviewed candidates of the outcome within 45 days of their final interview and keep a record for three years.

• Record retention: Employers must retain copies of publicly advertised job postings and associated application forms for three years. 

Additional changes needed to support Pay Transparency

The legislation also includes related provisions that are already in effect or are coming into effect soon: 

• Effective July 1, 2025: Employers with 25 or more employees must provide new hires with written information before or soon after their first day, including their starting wage, pay period, and work hours.

• Anti-reprisal protection: Existing legal protections prevent employers from punishing employees who discuss their compensation or ask about the company's compliance with the Act. 

  
  

What business leaders and owners need to do to prepare

To ensure compliance, Ontario employers are advised to take the following steps:

• Conduct a compensation audit: Evaluate your current compensation practices and pay structures to ensure they are fair and consistent, and to identify and address any unjustifiable pay discrepancies.

• Review hiring processes: Update job posting templates and hiring workflows to include compensation information, disclose AI usage, and remove "Canadian experience" requirements.

• Plan candidate communication: Establish a clear system for notifying interviewed candidates of hiring decisions within the 45-day deadline.

• Train staff: Provide training to HR and hiring managers on the new requirements and how to handle pay-related conversations with both candidates and existing employees.

For an even more in-depth understanding of Pay Transparency, see our prior article.

Our team at TAP Strategy & HR Consulting is equipped to help you prepare for this important legislative change. Give TAP a call at 613-222-2499, or email us at welcome@tapstrategyandhr.com