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Ontario Pay Transparency Law: What Employers Must Know

Ontario Working for Workers Act pay transparency AI hiring disclosure

Ontario's pay transparency requirements come primarily from the Working for Workers Four Act, 2024 (Bill 149), which amended the Employment Standards Act, 2000 (ESA). This legislation brought Ontario into alignment with other provinces and requires salary range disclosure in job postings. Ontario's approach is notable for also requiring disclosure of whether artificial intelligence is used in the hiring or screening process.

Who does the Ontario law apply to?

What must job postings include?

The AI disclosure requirement is unique among North American pay transparency laws and reflects Ontario's broader interest in algorithmic hiring transparency.

💰 Penalties: Violations of the ESA pay transparency requirements are enforced by the Ontario Ministry of Labour. Employers can face administrative penalties under the ESA, and the province has authority to impose significant financial consequences for non-compliance. Penalties under OHSA for associated violations can reach $500,000 for corporations.

Relationship to the Ontario Pay Equity Act

Ontario also has a longstanding Pay Equity Act that applies to most Ontario employers and requires pay equity plans and maintenance. This is separate from the job posting requirements under Working for Workers Four. Employers must comply with both.

Salary history prohibition

Ontario's Working for Workers Three Act (2023) prohibits employers from asking applicants about their pay history as a condition of considering them for employment. This applies to all Ontario employers regardless of size.

Employer checklist

How RoleComply helps Ontario employers

RoleComply checks Ontario job postings for salary range inclusion and flags missing disclosures. For employers using AI tools in hiring, RoleComply also checks whether AI disclosure language is present in applicable postings — a compliance requirement many employers initially overlook.

What employers in Ontario must do

The Ontario Pay Equity Act is the authoritative source for compliance requirements in this jurisdiction. Regardless of the specific status of local legislation, employers in Ontario should treat pay range disclosure as a baseline requirement today — the direction of travel is clear, and proactive employers are already ahead.

Audit all job postings. Pull every active role from your careers page, LinkedIn, Indeed, and any job boards or agencies posting on your behalf. Verify each posting includes a wage or salary range. Where ranges are missing, add them. Where ranges exist but are placeholder-wide, replace them with real, defensible figures connected to your compensation structure.

Build formal pay bands. The range you post must reflect what you would actually pay. This requires a compensation framework: roles mapped to levels, benchmarked externally, with documented criteria for where within a band an individual employee sits. Without this, you cannot post credible ranges consistently.

Remove salary history questions. Pay transparency legislation consistently prohibits asking candidates about their current or previous salary. Review your application forms, recruiter screening scripts, and any pre-employment questionnaires to ensure salary history questions have been removed entirely.

The business case for going further

Employers who post salary ranges report better application quality, faster time-to-fill, and stronger employer brand scores. Candidates self-select based on realistic expectations, offer acceptance rates improve, and internal pay equity conversations become easier when compensation is documented and transparent. The compliance obligation is the floor — the strategic opportunity is considerably higher.

Read our pay transparency fundamentals guide for the full picture, or see our remote work compliance guide for managing obligations across multiple Canadian provinces.

Legal disclaimer: This article is for informational purposes only and does not constitute legal advice. Pay transparency laws are complex and subject to change. Consult qualified legal counsel before making compliance decisions. RoleComply monitors law changes automatically, but always verify requirements with an attorney for your specific situation.

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