Ontario Bill 149 Pay Transparency Rules: Compliance Guide for Employers (2026)

Summary

Ontario’s Bill 149 (Working for Workers Four Act, 2024) introduces mandatory pay transparency and other hiring rules for employers with 25 or more employees in Ontario. These requirements took effect on January 1, 2026, and apply to all publicly advertised job postings.

Key obligations include disclosing salary information, stating vacancy type, disclosing AI use in screening (if applicable), banning Canadian work experience requirements, notifying interviewed candidates of hiring decisions within 45 days, and retaining records for three years. Federally regulated industries are exempt. This blog will help you determine applicability, understand requirements, and build compliant processes for your business.

Who does Bill 149 apply to?

Bill 149 applies to Ontario employers with 25 or more employees (including full-time, part-time, and seasonal staff) as of January 1 each year. The employee count focuses on those employed in Ontario.

Small businesses with fewer than 25 employees are exempt, though monitoring future changes is advisable.

Federally regulated sectors (e.g., banking, telecommunications, interprovincial transportation) follow federal rules instead. Confirm your sector's jurisdiction if needed.

Key pay transparency requirements under Bill 149

The law mandates several obligations for publicly advertised job postings (e.g., job boards, company websites, social media, print ads):

 These rules promote fairness, informed decisions for applicants, and inclusive hiring.

Pay transparency vs. pay equity

Pay transparency means openly sharing salary details in postings to build trust and visibility. 

Pay equity ensures equal pay for work of equal value, addressing protected characteristic-based gaps. 

Step-by-step guide to building a pay transparency policy

1. Audit current compensation data 

Collect pay rates, bonuses, and incentives. Compare similar roles, identify disparities, and update to market rates.

2. Establish salary bands and rationale 

Define ranges based on responsibilities, skills, experience, education, market rates, and internal fairness.

3. Draft a written pay transparency policy 

Include purpose, methodology for ranges, disclosure procedures, employee inquiry process, and compliance measures.

4. Train hiring managers and supervisors 

Cover explaining ranges, handling pay questions, and documenting AI use.

5. Communicate policy changes to employees 

Share the policy's purpose and details to build trust.

6. Conduct annual pay audits

Review structures using market data to stay competitive and compliant.

Updating job postings and recruitment workflows

Use clear salary range language: For e.g., “Hourly wage: $20.00–$24.00, based on experience” or “Annual salary: $50,000–$60,000.” Avoid “competitive salary.”

Remove Canadian experience requirements: Replace with inclusive terms to attract diverse talent.

Notify interviewed applicants within 45 days: For publicly posted jobs, update all interviewed candidates on the hiring decision within 45 days of their final interview.

Create a clear AI disclosure statement: Use concise language if AI applies.

Record-keeping for compliance: Retain for three years: job postings, applications, interview notes, compensation ranges, AI statements, and candidate notifications.

Avoiding common pitfalls for small businesses

Balance pay range flexibility: Avoid overly wide or narrow ranges; align with market rates for clarity and negotiation room.

Align internal and external pay: Ensure posted ranges match current employee pay in similar roles.

Stay updated with market trends: Review salary surveys and competitor postings regularly.

Benefits of pay transparency for recruitment and retention

Builds candidate trust: Clear ranges help applicants assess fit, reducing uncertainty.

Strengthen your employer brand: Transparency differentiates you in competitive markets, attracting talent that values fairness.

Need expert HR support for Bill 149 compliance?

Peninsula can help. Our experts provide tailored HR solutions for implementing Bill 149 requirements, including contracts, employee handbooks, policies, and guidance on HR, Health & Safety, and employee matters. Our certified HR experts are available 24/7. To learn more about how our services can help your business, call us today at (1) 833-247-3652.