Link to Ontario’s Working for Workers Four Act, 2024 changes the Employment Standards Act. Ontario’s Working for Workers Four Act, 2024 changes the Employment Standards Act.
From January 1, 2026, employers with 25 or more employees must say in any publicly advertised job posting if AI is used to screen, assess, or select applicants. You must also include the same note in any associated application form.
This sits beside other new posting rules, such as pay range disclosure and the prohibition on requiring “Canadian experience” in job postings.
Who is covered
- Employers in Ontario with 25 or more employees.
What must be disclosed
A clear statement that your hiring process uses AI at any stage to screen, assess, or select candidates. Ontario has adopted a broad definition of AI, and the obligation is disclosure, not a full technical report. Expect further guidance as the effective date nears.
Sample disclosure statements you can copy
Pick one and tailor it to the tools you actually use.
- “We use AI-enabled tools to sort applications based on job-related criteria. A human decides who moves forward.”
- “Our hiring process includes AI screening for keywords and minimum qualifications. Recruiters review all results.”
- “Video interviews may be scored with AI. Trained staff review the scores before any decision is made.”
Tip: Keep it short, accurate, and visible on both the job ad and the application page. HR teams should be ready to answer candidate questions about AI use.
Your 6-step compliance checklist
- Inventory your tools. Note any software that ranks, filters, or scores candidates.
- Decide what the tool does. Screening, assessing, selecting—or all three. Write it down in plain English.
- Add disclosure lines to every posting and application form in advance of the deadline, ideally by December 2025.
- Post pay ranges and remove “Canadian experience” requirements to prepare for the full 2026 posting rules package.
- Train your team on how to answer candidate questions about AI.
- Keep a human in the loop. Use AI to assist, not replace, decision makers.
FAQs
- Do we need to name the vendor or publish model details?
- No. The Act requires disclosure of AI use, not technical specs. Keep it clear and accurate.
- Does this apply to generic “Help Wanted” signs?
- No. The duty targets publicly advertised postings, not generic notices.
- Is there guidance on exact wording?
- Not yet. Legal commentators expect more direction before 2026, so monitor updates.
Need a quick policy refresh before year-end planning? SpringLaw can review your hiring tools, draft compliant disclosure language, and train your team.