Collected Perspectives: Shared Management Wisdom from Stratford

Ontario’s New Pay Transparency Rules: What HR Needs to Know

Written by Stratford Group Ltd. | Sep 18, 2025 3:52:15 PM

Ontario’s new pay transparency and onboarding rules will be mandatory for many organizations by 2026, but smart HR, Compensation, and Total Rewards leaders aren’t waiting until then. These changes are forcing a shift in how you structure roles, share salary info, and close the loop with candidates. This might sound like more red tape, but it’s also a critical opportunity to strengthen compensation governance, reduce risk, and align hiring workflows with your employer brand. Here's how to prepare now, and how Stratford Group can support your team.

 

This Isn’t Just a Compliance Checkbox—It’s About Credibility

HR teams are being handed a rare chance to reset how pay is communicated and managed. Yes, Ontario’s new rules are a compliance requirement—but if that’s all you see them as, you’re missing a bigger opportunity.

Done well, these updates can help your team:

    • Boost trust in hiring practices
    • Strengthen pay governance
    • Align job postings with your employer brand
    • Demonstrate that HR is thinking strategically and proactively

The right prep now will save your team hours (and headaches) later.

 

What’s Actually Changing?

Ontario’s Employment Standards Act, 2000 (ESA) sets the minimum standards for most workplaces in the province—things like hours of work, vacation time, public holidays, and now, pay transparency. The recent amendments add new requirements that directly impact how you post jobs, share compensation details, and handle hiring records.

There are two major rule changes you need to be aware of:

    • July 1, 2025 (Already in effect) → New onboarding disclosure rules are introduced.
    • January 1, 2026 → Broader job posting and transparency requirements become mandatory.

If your organization has 25 or more employees and hires for roles in that could be filled by Ontario-based candidates (even if the role is remote), these updates will apply to you.

→ It’s not just about where your office is. If your job posting reaches Ontario candidates, you’re likely within scope.

 

Are You Aligned with the New-Hire Requirements Already in Effect?

The first phase of Ontario’s pay transparency legislation is already live. As of July 1, 2025, employers with 25 or more employees must meet new onboarding disclosure requirements.

That means before an employee’s first day, you need to provide—in writing—the following information:

    • Your business’s legal and operating name
    • Contact information
    • Work location (remote, hybrid, or onsite)
    • Starting pay rate
    • Pay schedule (weekly, biweekly, etc.)
    • A description of their initial hours of work

→ Tip: If you’re still relying on older offer letter templates or inconsistent onboarding processes, now’s the time to tighten them up. The regulation is already in force, and auditors won’t wait for your HRIS to catch up.

This rule is about more than checking a box. Clear, consistent pre-employment communication helps:

    • Set expectations
    • Reduce friction in early employment
    • Limit legal risk
    • Reinforce your employer brand

If you haven’t done an onboarding compliance check this quarter, make it a priority.

 

Are Your Job Postings Ready for What’s Coming in 2026?

The next major milestone lands on January 1, 2026. That’s when new job posting standards kick in, potentially changing how you advertise roles, communicate compensation, and follow up with candidates.

Publicly advertised job postings in Ontario must include:

    • Compensation disclosure: Either a fixed pay rate or a salary range. If using a range, the spread must be $50,000 or less, unless the top end exceeds $200,000, in which case disclosure is optional.

→ Tip: Ranges should reflect reality. Avoid using placeholder numbers or “open” language—misaligned pay expectations are hard to walk back, and could hurt your employer brand.

    • AI usage disclosure: If artificial intelligence is used to screen, assess, or select applicants (either directly or via third-party tools), this must be clearly stated in the posting.

→ Tip: Many organizations aren’t aware their ATS or testing tools are powered by AI. Confirm with vendors and flag this in your recruitment playbook.

    • Vacancy status: If the posting is tied to an existing vacancy, this must be a statement to that effect in the job posting.

→ Tip: If you post roles on a rolling basis, make sure to clarify that—vague postings could raise compliance flags or create confusion for applicants.

    • No “Canadian experience” requirement: Job postings may not request “Canadian experience” from applicants.

→ Tip: Focus on the capabilities that matter—skills, credentials, portfolio work, or task-based assessments. You may be surprised how much stronger your candidate pool becomes.

 

What About After the Interview?

Additionally, these new requirements set expectations for what happens after a candidate is interviewed.

    • Candidate Outcome Notifications: if someone interviews for a role, they must be notified of the outcome—verbally or in writing—within 45 days of the interview.

→ Tip: Don’t rely on good intentions. Assign clear responsibility (HR or hiring manager?) and consider automating reminders in your ATS. This small but important step reinforces professionalism and trust—even if the candidate isn’t hired.

 

What Does This Mean for HR and Total Rewards Leaders?

New pay transparency rules may feel like just another compliance hurdle. But for HR and Total Rewards leaders, they’re also a chance to sharpen compensation governance, simplify hiring processes, and strengthen your team’s credibility inside the business.

Here are six priorities to tackle between now and January 2026—with practical steps to start now and ways Stratford can help.

 

1. Your Salary Ranges Must be Grounded in Reality

Now is the time to tighten your job architecture and salary bands. Ranges must reflect actual pay practices—especially in public-facing postings.

Action steps:

    • Audit your job architecture and identify outdated or inconsistent bands.
    • Refresh salary ranges to meet the ESA’s $50K spread requirement.
    • Benchmark against reliable market data to confirm competitiveness.

Where Stratford fits: We help teams recalibrate salary structures, validate equity, and ensure public ranges are both compliant and defensible.

 

2. Your Use of AI in Hiring Needs to Be Audited and Understood

Many organizations use ATS tools or third-party assessments that include AI in candidate screening. Identify where AI is in use so you can disclose it accurately and meet regulatory expectations.

Action steps:

    • Inventory your recruitment tech stack to flag where AI shows up.
    • Update job posting templates with disclosure fields where needed.
    • Train recruiters and hiring managers on what AI use actually means.

Where Stratford fits: We work with clients to review hiring workflows, identify hidden AI use, and set up systems to track disclosures consistently.

 

3.  Job Ads Need to Shift from Preference to Competency

The elimination of “Canadian experience” isn’t just semantics—it’s a push toward skills-first hiring. This means shifting to objective indicators like licenses, portfolios, or practical assessments.

Action steps:

    • Rewrite job postings with skills-first language.
    • Replace “experience” shortcuts with credentials, certifications, or work samples.
    • Communicate new expectations to hiring managers.

Where Stratford fits: We support HR leaders in building inclusive, competency-based posting frameworks that expand candidate pools and strengthen brand reputation.

 

4. Candidate Follow-up Needs a System, Not Just Good Intentions

Whether centralized through HR or delegated to hiring managers, your team must implement a consistent 45-day follow-up process post-interview. This may seem simple in theory, but could get messy in practice without clear workflows.

Action steps:

    • Decide who owns outcome communication (HR vs. hiring manager).
    • Configure your ATS or HRIS to track candidate timelines.
    • Standardize templates and scripts for consistent messaging.

Where Stratford fits: We help clients configure systems and create light processes that make compliance seamless—even during high-volume hiring.

 

5. Understand the Scope of the Regulation, But Plan for Consistency

Not every posting qualifies: Internal-only roles, postings outside Ontario, or those not tied to a vacancy may be exempt. Still, erring on the side of clarity and consistency is wise and reduces confusion.

Action steps:

    • Clarify which postings legally qualify and which don’t.
    • Decide whether to apply one consistent standard across all postings.
    • Document and share your internal policy.

Where Stratford fits: We help organizations design practical policies that balance compliance with efficiency.

 

6. Onboarding Isn’t Just a Form—It’s a Compliance Moment

Treat your onboarding process as more than paperwork—it’s the first impression of your culture.

Action steps:

    • Audit and update offer letters, onboarding packages, and HRIS templates.
    • Train managers to reinforce pay, schedule, and work location clarity.
    • Create a candidate-facing resource (“How Pay Works Here”) to strengthen transparency.

Where Stratford fits: We help HR teams streamline onboarding documentation, align it with ESA standards, and use it as an opportunity to boost candidate trust.

 

How Stratford Group Can Help

The new transparency requirements aren’t just about compliance—they’re a chance to reset. For HR and Total Rewards leaders, this is an opportunity to align pay practices with strategy, modernize hiring workflows, and build trust with both employees and candidates.

Stratford’s Total Rewards consulting team is already supporting Ontario-based clients to:

    • Recalibrate job architecture and pay ranges so they’re both compliant and competitive
    • Benchmark roles against reliable market data and run equity checks
    • Configure ATS and HRIS systems to handle posting metadata and 45-day notifications
    • Equip managers with consistent, candidate-ready communications

If you want a structured roadmap to get started, our ESA Readiness Checklist lays out a practical 60-day action plan.

→ Download ESA Readiness Checklist


For tailored support as you prepare for Ontario’s new ESA requirements, connect with us directly or visit our Total Rewards Consulting page.

 

About the Author

 

 

 

Jesse Dors is the Director of Total Rewards for Stratford People & Culture with more than 12 years of progressive experience in compensation and benefits. He has led teams at major Canadian organizations and has a strong track record developing, deploying, and maintaining remuneration programs. 

Jesse’s varied expertise in broad-based and executive compensation strategies provides a unique perspective to tackling total rewards challenges. He has a breadth of experience with organizational structure, benefit plans, job architecture, and people analytics. Recognized for his collaborative approach and fiscal responsibility, he brings a big-picture perspective to total rewards, advising Boards and executive teams on strategies that balance market competitiveness with organizational sustainability.