Ontario: AI Job-Posting Requirements under the Working for Workers Four Act, 2024 (Bill 149)

OntarioGuidanceIn force

Under the Employment Standards Act, 2000 (ESA), Ontario requires employers advertising publicly advertised job postings to include a statement disclosing their use, if any, of artificial intelligence (AI) to screen, assess, or select applicants. The rule applies to external job postings for specific positions advertised on or after January 1, 2026, by employers employing 25 or more workers in Ontario. Employers remain responsible for including this disclosure even if they utilize a third party or recruitment agency to post jobs on their behalf. The law defines AI broadly as machine-based systems inferring outputs to influence physical or virtual environments. While a detailed technical description of the AI tool is not required, the posting must explicitly state that AI is used in candidate screening, assessment, or selection. Employers must also retain copies of all publicly advertised job postings and linked documents for three years after public access is removed.

Impact

What this means for HR and vendors

HR and recruitment teams

HR and recruitment teams employing 25 or more workers in Ontario must ensure all external, publicly advertised job postings posted on or after January 1, 2026, disclose whether AI is used to screen, assess, or select job candidates. Organizations using AI screening tools or third-party recruiters must establish standardized disclosure templates and review vendor posting practices. Additionally, HR operations must retain copies of every public job advertisement, including linked content and revised versions, for three years following removal.

HR technology vendors

HR technology vendors supplying AI screening, assessment, or candidate selection tools to Ontario employers face indirect commercial expectations to support client compliance. While the statutory duty to include AI disclosures in job postings rests on deployers, vendors must inform employer customers whether their tools utilize artificial intelligence under Ontario's definition. Providers must also support deployers by maintaining system transparency so employers can accurately state when AI is involved in filtering or assessing applicants.

Key obligations

What organizations need to do

Practical obligation briefings focused on what the requirement is, who it applies to, when it applies and what teams should consider doing.

DeployerTransparency & Notice

AI Disclosure in Publicly Advertised Job Postings

DeployerDocumentation & Recordkeeping

Job Posting Record-Keeping

OBLIGATION

APPLIES TO

STATUS

Stay ahead of AI hiring compliance before it lands.

Free alerts on the regulation, litigation and incidents shaping AI in hiring.

Not legal advice

This page is regulatory intelligence only. Organizations should seek guidance from legal counsel before making compliance decisions.

Employment-focused extraction

This may be part of wider regulation. The Warden Watch extracts and displays the parts relevant to employment, HR and recruitment decision-making.